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Environmental management systems

Basic concepts of ISO 14001

John Stans & Maarten A. Siebel

UNESCO - IHE, Delft, The Netherlands

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CONTENTS

4. ENVIRONMENTAL MANAGEMENT SYSTEMS 1

4.1. PURPOSE AND BENEFITS OF AN EMS 1


4.1.1 INTRODUCTION 1
4.1.2 INTERNATIONAL DEVELOPMENTS SINCE THE 1970'S 2
4.1.3 ENVIRONMENTAL MANAGEMENT 3
4.1.3.1 Finance 4
4.1.3.2 Stakeholder pressure, awareness, image, reputation 5
4.1.3.3 Competitiveness 6
4.1.3.4 Legislation and enforcement 8
4.1.4 ENVIRONMENTAL MANAGEMENT SYSTEMS 8
4.1.5 THE E-EFFICIENCY TOOL – TO GET A HANDS-ON FEELING 9

4.2. BASIC CONCEPTS OF ISO 14001 11


4.2.1 ISO 14001: STRUCTURE AND BASIC CONCEPTS 11
4.2.1.1 Structure 11
4.2.1.2 The Deming Cycle 12
4.2.1.3 The contents of ISO 14001 13
4.2.1.4 Basic concepts in ISO 14001 15
4.2.1.5 Summary of Procedures, Documents and
Records referred to in ISO 14001 23

4.3. EMS REQUIREMENTS (NO LECTURE NOTES ON THIS CHAPTER)

4.4. ENVIRONMENTAL POLICY 26


4.4.1 INTRODUCTION 26
4.4.2 A LOOK AT ISO 14001 27
4.4.2.1 What ISO 14001 requires you to do 27
4.4.2.2 Interpretation 28
4.4.2.3 Documents and records 29
4.4.3 PRACTICAL GUIDANCE 29
4.4.3.1 Developing the policy 29
4.4.3.2 The content of the policy 30
4.4.3.3 Publicising the Environmental Policy 32
4.4.3.4 Implementing the policy 33
4.4.3.5 Revising and improving the policy 33
4.4.4 ENVIRONMENTAL POLICY: EXERCISE 34
4.4.4.1 Exercise: Environmental Policy 34
4.4.4.2 Exercise: Emergency Preparedness And Response 36
4.4.4.3 Exercise: Environmental Auditing 37

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4.5. THE INITIAL ENVIRONMENTAL REVIEW 39
4.5.1 THE INITIAL ENVIRONMENTAL REVIEW 39
4.5.1.1 What is the Initial Environmental Review? 39
4.5.1.2 Methodology 40
4.5.1.3 Carrying out the review 44
4.5.1.4 Reporting 46
4.5.1.5 Reference manual 47
4.5.1.6 A basis for the Environmental Policy 48
4.5.2 INITIAL ENVIRONMENTAL REVIEW EXERCISE 49
4.5.2.1 Case Study 49
4.5.2.2 Exercise: Identifying Environmental Aspects and
Impacts 54
4.5.3 INITIAL ENVIRONMENTAL REVIEW PROTOCOL 57

4.6. ENVIRONMENTAL AUDITING EXERCISE 71


4.6.1 EXERCISE: ENVIRONMENTAL AUDITING 71

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4.2. BASIC CONCEPTS OF ISO 14001

4.2.1 ISO 14001: STRUCTURE AND BASIC CONCEPTS

4.2.1.1 Structure

ISO 14001: Environmental Management Systems – Specification with guidance for use,
was established in September 1996 after a process of intense discussion in the Working
Group under Subcommittee 1 in ISO/TC207 (Technical Committee on Environmental
Management).

ISO 14001 has been established with the purpose to be applicable for all kinds or
organisations, regardless their nature and size, and for all geographical, cultural and
social conditions.

The success of the system depends on the commitment on all levels in the organisation,
especially the highest management level.

The standard only contains the requirements that can be checked objectively. This may
serve a purpose for certification and registration and for self-declarations by the
organisation.

The standard doesn’t contain absolute environmental performance requirements, except


the obligation to comply with legislation and the commitments to continual improvement
and prevention of pollution. Therefore it is possible that two organisations with
comparable activities produce different levels of environmental performance, but both
comply with the ISO 14001 requirements.

The standard is using the same general management system principles as the ISO 9000
series, which is the series for quality management systems. Organisations may choose
to use their existing ISO 9000 quality management system to include additional
environmental management system elements.

ISO 14001 consists of:

• A specification part that presents the requirements that need to be met as a


minimum.
• An Informative Annex that serves to increase the understanding of the requirements
and that has been designed ‘not to subtract nor to add any requirement of the
standard’. This Informative Annex is a very valuable tool for a better understanding
of the specification part.
• Cross reference tables that are included to show the linkage between ISO 9000 and
ISO 14001 requirements.
The table starting with ISO 9000 requirements is to be used by organisations that
have already established a Quality Management System and want to have a quick
overview of the way in which the requirements of the EMS are related to the ISO
9000 requirements. Organisations that have used ISO 14001 for developing their
EMS will be able to use the table that starts with ISO 14001-requirements to see
where linkages with ISO 9000 are as soon as they want to develop a Quality
Management System.

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Apart from ISO 14001 there is also an ISO 14004-standard: Environmental Management
Systems – General guidelines on principles, systems and supporting techniques. ISO
14004 is a guidance document. It contains a further description of the elements of ISO
14001. As such, ISO 14004 is not a mandatory document when an organisation wants to
develop and implement an EMS according to ISO 14001. It does not contain
requirements of its own; it is not referred to as a mandatory interpretation of ISO 14001.
However, if an organisation wants to use all the information sources on the development
of an EMS that are available, then ISO 14004 is worthwhile reading. The informative
annex in ISO 14001 is also useful in this regard.

4.2.1.2 The Deming Cycle

The ISO14001 standard has been structured according to a sequence that has come to
be known as the Deming cycle. Dr. Deming, a statistician by original training, designed
statistical control methods that have been used in World War II by the USA. After the
war, his concepts and ideas did not receive much attention in the USA, one of the
reasons why he decided to go to Japan. There, his ideas on statistical control and quality
management concepts became very well used.

One of the concepts he developed was the sequence of steps one has to go through for
a successful controlled process. He advocated the following steps:

• Plan: a planning phase – the overall objectives and goals of the enterprise are
established and the methodologies for achieving them are developed
• Do: an action phase – the plan is implemented and the agreed measures are taken in
pursuit of the enterprise’s goals
• Check: an evaluation phase – the actions taken under the plan are checked for
effectiveness and efficiency, and the results are compared to the plan
• Correct / improve: a corrective action phase – any deficiencies or shortcomings
identified are repaired, the plan may be revised and adapted to changed
circumstances, and procedures are reinforced or reoriented as necessary.
Furthermore, Deming emphasised that goals are never fully achieved and process
improvement is never ending. The situation inside and outside of the organisation may
have changed or will change in the near future. Therefore corrections may at the same
time need to include improvement actions.

Plan
Plan

Act
Act Do
Do

Check
Check

Figure 4.2: The Deming Cycle

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4.2.1.3 The contents of ISO 14001

The basis of the standard is the following reasoning:

The EMS is aimed at formulating and achieving an adequate environmental policy in the
organisation.

Therefore the significant environmental aspects need to be identified, as well as the


applicable requirements from the environmental legislation. Based on this knowledge the
environmental policy is established, together with objectives, targets and an
environmental programme to achieve these objectives and targets.

To be able to realise the environmental programme and to achieve control of the


activities that are critical for the environment, the organisation needs to establish several
organisational measures. The level of control, but also the effects of this control need to
be measured, recorded, analysed and evaluated. Where necessary corrective measures
need to be taken. The correct functioning of the EMS is reviewed by system audits.
Management reviews evaluate the continuous suitability of the EMS and can lead to
revisions of policy, objectives and targets. After this the control and improvement cycle
will start again.

The table of contents of ISO 14001 is shown below.

Three Annexes are included: Annex A on Guidance on the use of the specification,
Annex B on links between ISO 14001 and ISO 9001 and an Annex C on Bibliography.

Foreword

Introduction

1 Scope

2 Normative References

3 Definitions

4 Environmental management system requirements

4.1 General

4.2 Environmental policy

4.3 Planning

4.3.1 Environmental aspects

4.3.2 Legal and other requirements

4.3.3 Objectives and targets

4.3.4 Environmental management programme(s)

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4.4 Implementation and operation

4.4.1 Structure and responsibility

4.4.2 Training, awareness and competence

4.4.3 Communication

4.4.4 Environmental management system documentation

4.4.5 Document control

4.4.6 Operational control

4.4.7 Emergency preparedness and response

4.5 Checking and corrective action

4.5.1 Monitoring and measurement

4.5.2 Non-conformance and corrective and preventive action

4.5.3 Records

4.5.4 Environmental management system audit

4.6 Management review

Annex A Guidance on the use of the specification

Annex B Links between ISO 14001 and ISO 9001

Annex C Bibliography

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Continual Improvement
Environmental Policy

Planning PLAN
• Environmental aspects
• Legal & other requirements
Management Review ACT • Objectives & targets
• Env management programme

Implementation & Operation


• Structure & responsibilitiy DO
• Training, awareness & competence
Checking & Corrective Action • Communication
• Monitoring & measurement • EMS Documentation
• Non-conformance, corrective & • Document control
preventive action • Operational control
• Records • Emergency preparedness and response
• EMS audit CHECK

Figure 4.3: The elements of ISO 14001

4.2.1.4 Basic concepts in ISO 14001

4.2.1.4.1 Environmental Aspects and Impacts


One of the important concepts in ISO 14001 is the distinction that is made between
aspects and impacts.

Environmental impacts are defined as:

Any change to the environment, whether adverse or beneficial, wholly or partially


resulting from an organisation’s activities, products or services.

An EMS cannot directly influence the environmental impacts. It is focussed on the


causes of the environmental impact. For these causes ISO 14001 uses the term
environmental aspect.

An environmental aspect is defined as:

Element of an organisation’s activities, products or services that can interact with the
environment.

The distinction between aspects and impacts has been shown in Figure 4.4.

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Suppliers

A
Company S Environment
E P I
M
M Activities E P
S Products
C A
Services C
T T
S
S
Clients

Figure 4-4: Environmental aspects and impacts

The figure also shows that some of the aspects may not be directly caused by the
organisation, but possibly by suppliers, contractors or by the clients when using the
products. This has been taken into account in ISO 14001 by requiring that the EMS does
not only consider the aspects of the organisation itself but also those which the
organisation can influence (see section 4.3.1).

4.2.1.4.2 Focus on Significant Environmental Aspects

Organisations can identify hundreds or thousands of environmental aspects, depending


on the level of detail in the analysis of its activities. ISO 14001 does not require an
organisation to consider all their aspects, but only those which are considered significant.

A significant environmental aspect is defined as:

An environmental aspect that has or can have a significant environmental impact.

An important question to be asked is what is a significant environmental impact. Here,


ISO 14001 does not provide clear direction. ISO 14004 can be used to give assistance. It
states that significance can be associated with environmental concerns such as the
scale, the severity, the duration and the probability of the impact, as well as by business
concerns. Business concerns can include the potential regulatory and legal exposure,
concerns of interested parties, effects on public image, difficulty of and the cost of
changing the impact and the effects of change on other activities and processes. Figure
4.5 illustrates the process.

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One of the consequences of these criteria is that as soon as legislative or regulatory
requirements, permits and similar requirements refer to a specific environmental impact,
the associated environmental aspects should be considered significant. This listing is not
comprehensive and should not be considered as prescriptive.

Environmental Significance Significant EMS core elements


aspects criteria based aspects (selection)
on potential
impacts

Policy
History Scale
History
Severity Objectives &
Probability targets
Suppliers Suppliers
Duration
Legislation Training
Cost and Process Awareness
difficulty of
Process changing the
impacts Operational
Interested control
Products
parties
Products
Image
Auditing

Reviewing

Figure 4.5: Significance criteria applied in selecting the significant environmental aspects

4.2.1.4.3 The commitments under ISO 14001


One of the first requirements in ISO 14001 is to develop and implement an
Environmental Policy. This has to be done by the organisation’s top management, and
the policy has to meet certain minimum requirements.

Some of these requirements are the commitments. These can be considered the
minimum performance levels the organisation agrees to comply with.

These commitments are:

• To comply with relevant environmental legislation and regulations


• To comply with other requirements to which the organisation subscribes.
• To commit to continual improvement and
• To commit to prevention of pollution.

What is the consequence of these four commitments? Many organisations struggle for
some time trying to understand the consequences of the commitments they have
accepted. The consequences are described in the following sections.

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4.2.1.4.4 Legislation and other requirements
With regard to legislation and other requirements, the organisation needs to ensure that
it:

• Has knowledge of the environmental legislative requirements on the organisation,


• Has established measures and mechanisms to enable the organisation to comply,
• Has mechanisms in place to measure and monitor any deviation from compliance
and corrective mechanisms to address deviations, and
• Has functioning reporting mechanisms in place if reports are to be made to
authorities on environmental aspects.
This also means that compliance with legislation needs to be the starting position for the
organisation, instead of a long-term goal.

Compliance with legislation can therefore not be regarded as a goal that can be reached
through continual improvement. At the moment an organisation wants to go for ISO
14001 certification the compliance with legislation should be there.

Some special conditions that deviate from compliance are acceptable for certification:

• Occasional deviations, that are observed through measuring and monitoring, for
which corrective mechanisms need to start soon after discovery,

• Cases where the organisation may need to invest in expensive technology or where
lengthy studies on improvement options need to take place. If the organisation can
agree with the responsible authorities on an action plan that works toward
compliance it is acceptable for certification,

• Cases where the organisation has applied for new licenses and did everything that
can be expected to supply the responsible authorities with the necessary information,
and where nevertheless, the necessary new licenses have not been issued. In these
cases, the certification is still possible, if sufficient evidence is available that all the
steps under the influence of the organisation have been performed and that the
remaining steps are outside of the sphere of influence of the company.

Examples of ‘other requirements’ include the ICC Business Charter for Sustainable
Development, the Responsible Care programme, and also voluntary agreements with
sector organisations or with authorities.

If the organisation has signed specific codes, the organisation must be able to identify
the requirements to be fulfilled and how this will be done. Where the organisation has
only recently signed, it should be able to show an implementation plan.

4.2.1.4.5 Continual Improvement and prevention of pollution


A very important concept in ISO 14001 is that of continual improvement.

ISO 14001 defines continual improvement as:

Process of enhancing the EMS to achieve improvements in overall environmental


performance in line with the organisation’s environmental policy.

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Added to the definition there is a note saying that the process need not take place in all
areas of activity simultaneously.

Figure 4.6 shows that the EMS can be visualised as a wheel that has to be pushed or
pulled towards higher performance levels. The wheel is stopped from slipping back via
quality and environmental controls.

continual
improvement
Performance sustainable
plan do development
act check

assurance (quality / environment)

time

Figure 4.6: Continual Improvement

In environmental management the ultimate goal is the level where the principle of
Sustainable Development applies. Sustainable development is a term that has been
introduced in 1987 by the World Commission on Environment and Development (also
called the Brundtland Commission after its chairperson) in their report Our Common
Future.

It is defined as:

Development that meets the needs of the present without compromising the ability of
future generations to meet their own needs.

A more popular version of the definition is that we have to realise that we have not
inherited the environment from our parents but that we have borrowed the environment
from our children. Therefore we should take care not to violate the limits of pollution and
other environmental impacts that the earth can absorb. This level is much lower than the
current levels of emissions. This is the reason why national environmental policies in
many countries aim at a dramatic reduction in pollution levels of the several sectors of
activity such as agriculture, traffic and industry.

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The consequence for organisations using ISO 14001 is that ISO 14001 expects to see
constant attention for possibilities for improvement of the EMS and environmental
performance.

Although ISO 14001 refers to the enhancement of the EMS, one cannot read in the
definition that only the improvement of the EMS is the aim of continual improvement.

First, the definition states that the higher goal is improvement of the overall
environmental performance. Second, planning activities such as setting objectives and
targets are mentioned explicitly in the EMS definition. Therefore, continual improvement
has the improvement of the environmental performance as the ultimate goal.

A difference between ISO 9000 and ISO 14001 requirements can be observed as well. In
ISO 9000, the main objective of improvement is better conformity with the requirements
or expectations of the client, as illustrated in Figure 2.6. ISO 14001 can be considered to
take this better conformity with requirements into consideration as well. At the same time,
it expects the organisation to set higher performance requirements on itself, beyond the
current legislative and regulatory requirements. Figure 2.6 presents these concepts.

It can be argued that in quality management client expectations are dynamic and
therefore the actual situation for quality management will resemble the picture drawn for
ISO 14001. It can be argued as well however, that, if the requirements of ISO 9000 and
ISO 14001 are compared, Figure 4.7 is best in line with the actual requirements for ISO
9000 and ISO 14001 respectively.

Continual Improvement
Performance
Requirements

ISO 9000
System
Development System Maintenance
Time
Sustainable Development
Performance Requirements

Continual Improvement
ISO 14000
System
Development System Maintenance
Time

Figure 4.7: Continual Improvement: ISO 9000 vs. ISO 14001

Prevention of pollution is defined in ISO 14001. It focuses on avoidance, reduction and


control of pollution using a wide range of measures such as efficient use of resources,
material substitution, process changes, control mechanisms, recycling and treatment.

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Because of this broad definition, organisations will normally be able to show that they
have measures in place that are covered by this definition.

4.2.1.4.6 Management and Control vs. Continual Improvement


An EMS according to ISO 14001 focuses on Significant Environmental Aspects, as
described in previous sections. The commitments in 2.4.4 have to be applied to these
significant environmental aspects. ISO 14001 contains a line of reasoning on how to deal
with the significant environmental aspects that is perhaps difficult to understand.

A basic requirement is that all significant environmental aspects need management and
control. Most of the elements of the system described in ISO 14001 are needed to
ensure that management and control are implemented, especially the elements dealing
with Implementation and Operation (the ‘Do’-step) and Checking and Corrective action
(the ‘Check’-step). Identification of significant aspects and identification of relevant
legislative requirements are an essential input to management and control.

A second requirement is the commitment to continual improvement and prevention of


pollution. That requirement refers to identifying possibilities for improvement and
ensuring that planned improvements are achieved. Elements that are relevant for this
process are the setting of objectives and targets and the environmental programme
arising from the Planning-step, as well as the Management Review. In identifying
possibilities for improvement, it is important to realise that ISO 14001 does not require
that improvement applies to all significant environmental aspects at the same time. In
setting objectives and targets, the organisation has to consider all its significant
environmental aspects, but it would be sufficient if only a fraction of the significant
environmental aspects are selected for setting objectives for them. Automatically the
other, remaining, significant environmental aspects will have to be managed and
controlled, instead of being improved. These two routes in ISO 14001 are visualised in
Figure 4.8.

Identify all Aspects Evaluate for


& Impacts Significance

Significance
Criteria

Minor Significant aspect


Aspect

Maintain Can it be managed or does


Record Manage it need improvement? Improve

Control Mechanisms Objective, Target,


required Programme
required

Figure 4.8: Dealing with environmental aspects in ISO 14001

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4.2.1.4.7 Documented procedures
ISO 14001 specifies documentation of procedures in only two sections:

• Under 4.4.6 it requires documented procedures in those cases where they are
necessary to prevent deviations from objectives and
• Under 4.5.1 documented procedures are required for measurements and monitoring
as well as for evaluating compliance.
In all other cases where procedures are required the organisation is not required to
document procedures.

If an organisation decides to document only the procedures for which documentation is


required in ISO 14001, it has to ensure that for the procedures that are required by ISO
14001, but that do not have to be documented, that:

• They can be communicated,


• They can be maintained and
• It can be demonstrated that they exist and that they are implemented and work
sufficiently well.

During the internal audit process and also during the certification audit process the
auditors would still be able to check that the procedures are in place by interviews and by
evaluating records.

However, many organisations have concluded that for the reasons mentioned above
there are arguments in favour of more documented procedures.

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4.2.1.5 Summary of Procedures, Documents and Records referred to in ISO
14001

In several places ISO 14001 requires procedures, documents and/or records.

4.2.1.5.1 Procedures
Table 4.1: Procedures

Section Subject

4.3.1 Identification of environmental aspects; determination of significance,


significant aspects

4.3.2 Identification of / access to legal and other requirements

4.4.2 Creating environmental awareness

4.4.3 Internal communication

4.4.3 Receiving, documenting and responding to relevant communication from


external interested parties

4.4.5 Controlling all documents required by the Standard

4.4.6 To cover situations where absence of procedures could lead to deviations from
the environmental policy and the objectives and targets

4.4.6 Related to the identifiable significant environmental aspects of goods and


services used by the organisation

4.4.7 Identification of potential for and response to accidents and emergency


situations and prevention and mitigation of associated environmental impacts

4.5.1 Monitoring and measuring key characteristics of the operations and activities
that can have a significant impact on the environment, including data to assess
performance, controls and achievement of objectives and targets.

4.5.1 Periodical evaluation of compliance with relevant environmental legislation and


regulations

4.5.2 Defining responsibility and authority for handling and investigating non-
conformances, taking action to mitigate impacts and initiating and completing
corrective and preventive action

4.5.3 Identification, maintenance and disposition of environmental records

4.5.4 Audits: scope, frequency, methodologies, responsibilities and requirements for


conducting audits and reporting results

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4.2.1.5.2 Documents
Table 4.2: Documents

Section Subject

4.2 Environmental policy

4.3.1 Method to determine the significant environmental aspects

4.3.3 Environmental objectives and targets

4.3.4 Environmental programme(s)

4.4.1 Organisational form and reporting lines

4.4.1 Roles, responsibility and authorities (including management representative(s))


for environmental activities and in general

4.4.4 ‘Manual’

4.4.6 Procedures for operational control

4.4.7 Emergency plan(s)

4.5.1 Procedures for monitoring and measurement, and for evaluation of legal
compliance

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4.2.1.5.3 Records
Table 4.3 Records

Section Subject
4.2 Evidence of involvement of top management in setting and approving the environmental policy

4.3.1 Identified environmental aspects (optional)

4.3.1 Identified significant environmental aspects

4.3.2 Identified legal and other requirements

4.3.2 Implementation plans for signed commitments that fall under the category ‘other requirements’

4.4.1 Proof of appointment of a management representative

4.4.2 Identification of training needs

4.4.2 Training records

4.4.2 Records of awareness training

4.4.3 Evidence of a communication structure and the functioning of this structure (minutes, reports)

4.4.3 Relevant communication from external interested parties

4.4.3 Decision on external communication on environmental aspects

4.4.3 Plan or procedure for external communication

4.4.3 Evidence that the chosen types of external communication are actually performed

4.4.7 Evidence of identification of potential accidents and emergency situations

4.4.7 Evidence of identification of prevention possibilities of emergency situations

4.4.7 Tests of emergency preparedness procedures

4.4.7 Evaluation of tests of emergency procedures and evidence of changes in the plan and procedures

4.5.1 Measurement and monitoring programme

4.5.1 Identification and calibration of monitoring equipment

4.5.1 Results of compliance evaluations

4.5.1 Results of measurements and monitoring

4.5.2 Evidence of arrangements for corrective and preventive action

4.5.2 Non-conformances and corrective and preventive actions

4.5.2 Changes in system documentation as a result of corrective and preventive action

4.5.3 Retention times of records

4.5.4 Audit programme(s), schedule

4.5.4 Audit reports

4.6 Document in preparation of the management review meeting(s)

4.6 Management review: frequency, contents and results

These records are not identified as records in ISO 14001. However, in the Standard
many requirements can be found on identification to take place, or similar wording.

It is our recommendation to consider records as the best way to give evidence that these
activities have taken place.

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