Case study for ISO 14001:2015

transition in a construction company

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Copyright ©2017 Advisera Expert Solutions Ltd. All rights reserved.

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Table of Contents

Executive summary ....................................................................................................................................... 3

Introduction .................................................................................................................................................. 3
Briefly about the company ........................................................................................................................... 4
Defining the timeframe and options for the transition ................................................................................ 4
Developing a Project Plan for the transition ................................................................................................ 6
Transition project.......................................................................................................................................... 7
Certification audit ....................................................................................................................................... 14
Conclusion................................................................................................................................................... 15
Sample documentation toolkit ................................................................................................................... 15

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Executive summary
With the arrival of ISO 14001:2015, organizations have been given three years to complete their move to
this new revision of the standard. All organizations currently certified against ISO 14001:2004 should
move to the latest version by September 2018 at the latest. This implies that after the end of September
2018, certificates based on ISO 14001:2004 will no longer be valid.

This case study will show you how a mid-size construction company started and finished the transition
project, the challenges it faced during the project, and solutions defined to overcome them.

Introduction
Time is the most vital factor for making the transition from ISO 14001:2004 to the latest 2015
revision. So, in order to transition with success, the company must begin on time and avoid
waiting till close to the deadline. Waiting until the last minute can leave less time to correct problems –
increasing the possibility of not being certified on time. It's vital to transition early, to cut back on the
risks and costs to your business.

The case study we are about to examine will show you the timeframes, and also the necessary activities
for a successful transition project.

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Briefly about the company
The company, let’s call it ABC Company, is constructing roads. It has 1000 employees and conducts its
business at various locations. ABC Company implemented ISO 14001:2004 in 2008, and put in charge an
Environmental Manager to deal with maintaining the EMS (Environmental Management System).

The reason for implementing the standard and getting the certificate was to enable the company to
become a subcontractor for Client A, which is a large road construction company holding big contracts
with the government and private sector.

Client A conducted regular second-party audits of ABC Company and the company was, on several
occasions, in danger of losing the contract because of the high number of nonconformities.

Defining the timeframe and options for

the transition
Client A invited the company to be a subcontractor in the new government project of revitalization of the
main highways, and this contract would enable the company to grow 20% in the next three years. The
only additional condition for the contract was to get certified according to ISO 14001:2015. The deadline
for the certification was in four months, and the company needed to start the transition immediately.

Although tempting, the contract would require purchasing new equipment, and the last thing the
company needed would be to invest money in the transition. The Environmental Manager conducted
some research on how to make the transition, and he presented the CEO with two options:

1. To hire a consultant – They had a really good relationship with their consultant and he was
always willing to help to resolve nonconformities emerging from the second-party audits. The
problem was, the consultant was too busy and he had several ongoing projects at the moment,
so he couldn’t dedicate completely to the project and the fees he required were too high for the
company at the moment.
2. To conduct the transition by themselves with some external help – The Environmental Manager
had been involved in the EMS for a long time and had good knowledge of the standard. He
didn’t need somebody to perform the transition; all he needed was help in the moments when

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 he got stuck with the new requirements. This option was far more cost effective, but it would
require some additional time.

Although the CEO liked the idea of saving money, his concern was that Client A, as their main customer,
would not let them prolong the transition because they had already insisted on aligning the EMS of the
company with ISO 14001:2015 as soon as possible. But, considering the need for new equipment and
other investments the company needed to make, the CEO decided to give the second option a shot.

The Environmental Manager suggested utilization of one of the numerous solutions available online, and
insisted on higher engagement of relevant people in the project. His idea was to employ “ready-to-use”
documentation templates, and to run the transition as a project by assigning responsibilities for certain
activities to the relevant people. In this way, they would spare some time on technicalities and multiple
people could finish different activities at the same time. (For more information on the timeframe needed
for the implementation, see: How long does it take to implement ISO 14001:2015?).

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Developing a Project Plan for the
transition
The CEO was chosen to be the sponsor of the transition project, considering the importance of the
transition for the company, and the Environmental Manager (EM) was the Project Manager.

The first step for the Project Manager was to determine how much work was ahead, so he decided to
conduct a gap analysis to determine to what level the company was already compliant with the standard,
and what needed to be done to achieve full compliance. Then, he needed to make an estimate and see
how many people he really needed on the project. (For more information about the gap analysis, see: Is
a gap analysis desirable for ISO 14001 implementation?).

The gap analysis showed that there were many documents to be updated in order to be aligned with ISO
14001:2015, and some additional processes needed to be implemented, such as determining context of
the organization and addressing risks and opportunities. Also, during the gap analysis, the EM identified
many areas of the EMS that could be optimized, although there were no changes in those requirements.

According to the gap analysis findings, the EM assembled a transition team that included heads of each
department and responsible persons for each process in the company. Each was given their role in the
project and assignments for different tasks; the deadline for the project was February 2017. The tasks
included writing new documents, updating old ones, and updating and developing new processes.

Activities related to clauses 4 (context of the organization), 5 (leadership), 6 (planning), and 7 (support)
were assigned to the EM and the top manager, while the rest of the team would help the EM to conduct
reassessment of the environmental aspects and design and implement operational controls.

(Here you’ll find a free ISO 14001:2015 Gap Analysis Tool.)

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Transition project
The EM presented the top management and the transition project team with Advisera’s 12-step transition
methodology. Each of the steps in the methodology was assigned to the relevant person. For more
information about the transition methodology, see: 12 steps to make the transition from ISO 14001:2004
to 2015 revision.

1) Determine context of the organization

The first requirement of the standard is to determine context of the organization in terms of the EMS
(Environmental Management System). Since the information about the context represents the
foundation for the EMS to be established, the EM took it very seriously and gathered all members of top
and middle management in the company to participate in this activity.

The EM presented the management with requirements of the standard and how they affected the EMS.
They decided to approach the requirement with a SWOT analysis. Each person in the top management
and the transition team would conduct the analysis independently, and the results would be merged into
a single document afterward.

Strengths Weaknesses
• Awareness of environmental issues • Outdated equipment
• Competent employees • Employee shortage
• Long-term contracts and steady income • ISO 14001 certificate according to old
• Experienced employees version of the standard
• Excessive cost of waste disposal
Opportunities Threats
• Winning public tenders • Losing contracts with big customers
Increasing competitiveness by getting ISO • Failing to meet deadlines for projects
14001:2015 certificate due to shortage in manpower
• Decreasing costs of waste disposal • Failing ISO 14001:2015 certification
Figure 1: SWOT analysis

For more information about determining the context, see: Determining the context of the organization in
ISO 14001.

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2) List all interested parties

As a part of determining context of the organization, the same team was involved in identifying interested
parties. They focused only on the interested parties related to the EMS and grouped them according to
their requirements. Because some interested parties were more important than others, they decided to
record these as separate entries in the list of interested parties.

Interested party Needs and expectations Responsible person

Ministry of Energy and Compliance with environmental Building Construction Manager
Environment protection legislation Environmental Manager
Ministry of Labor Occupational Health and Safety Building Construction Manager
regulations Road Construction Manager
Ministry of Transportation Regulations for road Road Construction Manager
construction
Subcontractors Environmental friendly raw Purchasing Manager
materials
Employees Adequate working environment Building Construction Manager
and personal protective Road Construction Manager
equipment Purchasing Manager
Client A ISO 14001:2015 certificate Environmental Manager
Figure 2: List of interested parties

As an addition to the list of interested parties, the company decided to add a responsible person for each
need and expectation. For more information about interested parties, see: Understanding the needs &
expectations of interested parties in ISO 14001.

3) Determining the scope of the EMS

At the moment when the standard was originally implemented, the company was considering expanding
its business to building construction, so they included it in the scope of the EMS. Later on, the idea was
dropped because the road construction was more lucrative and considering the company’s limited
resources, the top management decided to focus the business only on the road construction.

This information was never applied to the information about the scope in the Environmental Manual, and
the EM decided that this was the right moment to make this change.

Also, having a precise scope of the EMS left little room for any future nonconformities raised during the
certification or second-party audit. For more information about determining the scope, see: How to
determine the scope of the EMS according to ISO 14001:2015.

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4) Leadership and review of the Environmental Policy

As in a lot of other companies, the top management was only formally involved in the EMS. All the work
was performed by the EM. Meeting the requirements regarding leadership was always tricky, because
most of these requirements should be met through actions rather than documentation. The EM was
aware that without proper engagement of the top management it would be impossible to implement the
standard on time. Besides the direct requirement of the customer, the EM decided to organize an
awareness-raising session for the top and mid management and present them with benefits of ISO 14001.
For more information about the benefits, see: 6 Key Benefits of ISO 14001.

Having a chance to implement the standard by themselves, each manager from the company got a better
understanding of the standard, and thereby got better insight on how the standard could help them in
their line of work. The Environmental Policy was updated, through a joint effort from the top management
and the transition team, to meet all requirements of the standard. After the final approval of the CEO, it
was published on the website, presented to the clients, and read to the employees.

For more information about leadership requirements, see: How to demonstrate leadership according to
ISO 14001:2015.

5) Align EMS objectives with the company’s strategy

Because the top management didn’t play an important role in the EMS in previous years, the objectives
were written mostly by the EM, who usually just copied the objectives from the previous years. The
objectives were always written in a way that allowed easy fulfillment; so, on the surface, all looked good.

Now, the top management decided to give it a shot and define real objectives for the EMS, challenging
both the middle management and the company itself. Involvement of the top management in defining
environmental objectives ensured that they were aligned with the company’s strategy and general
direction.

The new version of the standard requires a new approach to defining objectives; besides defining SMART
objectives, the company must also define plans for achieving those objectives. The EM developed the
framework for planning achievement of the objectives; for each objective, the plan included defining the
responsible person, a set of activities that would lead to achievement of the objective, necessary
resources, and deadlines.

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 Plans for achieving the objective
EMS Deadline Responsibility Action to Resources Evidence of
objective achieve the needed the objective
objective achievement
All recyclable December Road Apply Human Deployed
waste must be 2017 Construction operational resources waste reports
deployed to Manager controls and
recycling perform
company regular
trainings for
the
employees
Expand February Purchase Get ISO Human New contract
contract with 2017 Manager 14001:2015 resources; with Client A
Client A certificate; $1000 for
Purchase know-how for
necessary the transition;
equipment $10,000 for
certification;
$500,000 for
new
equipment
Decrease fuel December Road Introduce new Human Fuel
consumption 2017 Construction equipment resources; consumption
by 10% Manager and improve $500,000 for records
compared to logistic plans new
2016 equipment
Figure 3: Environmental Objectives and Plans for their Achievement

Once the objectives and plans for their achievement were defined, the EM presented them to the relevant
people in the company.

For more information about defining environmental objectives, see: Ensuring that environmental
objectives are aligned with the company’s strategic direction.

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6) Assess risks and opportunities

Considering that all relevant people in the company participated in determining the context of the
organization, the risks and opportunities became clear from the start. Due to the short amount of time
for the transition project, the transition team decided not to define a methodology for addressing risks
and opportunities, but to arrange a brainstorming session with the top and mid management and talk
about the risks and opportunities in the company as a whole, and at the process level. The team decided
not to write a separate procedure for addressing risk and opportunities, but rather to amend the existing
procedure for identification and evaluation of environmental aspects with requirements for addressing
risks and opportunities.

As an input for the identification of risks and opportunities, they used the previously determined context
of the organization, records about previous nonconformities, significant environmental aspects, and
environmental incidents. This allowed them to identify all risks and opportunities relevant to the EMS and
to distinguish them by their significance to the company. After the significant risks and opportunities were
defined, they made plans for addressing risks and opportunities in a manner similar to their plan for
achieving environmental objectives. The plans included defining the activities, resources, responsibilities,
and deadlines.

For more information about risks and opportunities, see: Risks and opportunities in ISO 14001:2015 –
What they are and why they are important.

7) Identify and evaluate environmental aspects

When identification and evaluation of the environmental aspects was done for the first time during the
implementation of the standard, the EM had no help from other members of the mid management, and
with his limited knowledge of the processes, he did the best he could. The result was that some of the
environmental aspects were defined as significant when they shouldn’t be, and others were neglected.
Later, this led to a lot of redundant operational controls and nonconformities during second-party audits.

In order to prevent this from happening again, the EM asked process owners to engage in the
identification and evaluation process. Each process owner was assigned to conduct reassessment of the
environmental aspects within his own process and present the EM with the results. The reassessment
took far less time than the EM expected, since every process owner did a little portion of it. The Road
Construction Manager suggested that the EM also update the criteria for evaluation of the environmental
aspects so it would provide more consistent results.

This should have been done prior to the reassessment, but since the reassessment was done quickly, the
rest of the process owners agreed to conduct the assessment yet again, and the final result of this step
was a new Procedure for Identification and Evaluation of Environmental Aspects and Risks and a Process
Aspects Chart for every process.

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8) Determine compliance obligations

The company has never had problems complying with legal requirements, but it often had problems
during second-party audits conducted by Client A. They always managed to find some nonconformities
and force ABC Company to decrease prices or make some other compromise to maintain the contract.
The EM decided to put this practice to a stop.

Since ABC Company was a subcontractor of Client A, they have to follow Client A’s procedures and work
instructions, especially on the construction site. The EM and Road Construction Manager reviewed all the
documentation provided by Client A, compared them to their own work instructions and procedures, and
made a list of compliance obligations that needed to be met.

This list of compliance obligations contained not only the legal and regulatory requirements, but also
requirements of the clients formulated through contracts and any other means. Most of the clients had
the same requirements, so they were grouped as a one entity on the list, but because Client A had an
additional set of requirements, their requirements were recorded separately.

The EM decided to conduct regular evaluation of compliance obligations, aiming to avoid any major
nonconformities during future second-party audits.

For more information about compliance obligations, see: Compliance requirements according to ISO
14001:2015 – What has changed?.

9) Control of documented information

The company had one procedure for document control, and another one for record control. They were
rather long, with an overly robust document coding system and approval and withdrawal processes. The
rules for document and record control were too complicated and rarely used, which often led to
noncompliance and nonconformities in the past.

Having in mind the amount of documentation the company used on a daily basis, the EM decided to keep
the Procedure for Document and Record Control; he just updated it to meet the requirements of the new
standard and merged the two existing procedures into one.

For more information about document management, see: How to structure ISO 14001 documentation.

10) Operational control

The company already had some operational controls in place, but since the reassessment of
environmental aspects was conducted, the list of operational controls needed to be updated.

Some operational controls were discarded because the corresponding environmental aspects were no
longer considered significant, and there was a need for additional operational controls for the new
significant environmental aspects.

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The EM considered cost effectiveness to be one of the most important characteristics of the operational
control and tried to apply this approach when developing new and updating old operational controls. He
included process owners in defining operational controls for their own processes. This was most beneficial
because the process owners knew exactly what would be the most effective control, and how much
training would be needed for the employees who would be applying these controls.

Awareness is considered to be one of the key success factors in applying the controls, so the EM also
developed an awareness-raising plan along with the training plan and Procedure for Operational Control
of Significant Environmental Aspects, as well as other work instructions and guidelines for employees.

For more information about operational controls, see: Defining and implementing operational control in
ISO 14001:2015.

11) Environmental performance

The CEO always wanted to have a system of monitoring and measuring that could provide information on
the overall condition of the Environmental Management System. Internal audits were perceived to be an
overly robust and complicated approach, because they took too much time and effort, and because he
really didn’t need such comprehensive reports. But, he needed some information on these topics at a
more frequent pace.

The EM developed environmental performance indicators (EPI) for each operational control to determine
its performance, and the CEO required reports on the operational controls performance to be produced
on a monthly basis. This is not a requirement of the standard, but it had proven itself to be a useful tool
for getting a clear picture on what was going on in the EMS.

For more information, see: How to define EMS key performance indicators (KPIs) according to ISO 14001.

12) Measuring and reporting

The EM emphasized that he needed help not only in measuring, but also in reporting to the top
management, especially when it came to the internal auditing and preparing reports for the top
management. The CEO approved internal auditor training for all process owners in order to speed up the
internal audits, and also to avoid situations where the internal auditor audited his own work. (For more
information, see: Internal Audits in the EMS: Five Main Steps.)

The system slowly started to fall into place, and after monitoring and measuring key performance
indicators, compliance evaluation, and environmental incidents, the inputs for effective management
review started to become evident. After the internal audit was conducted and an internal audit report
was issued, all necessary data for the management review was ready.

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Certification audit
The results of the internal audit and management review were satisfactory and demonstrated success in
meeting the requirements of ISO 14001:2015. The CEO felt much more confident and decided to contact
the certification body even earlier than was defined in the project plan. To his surprise, their old
certification body hadn’t yet gained accreditation for ISO 14001:2015. So, they needed to hire another
certification body only because they needed the certificate as soon as possible.

After creating a survey and gathering offers from different certification bodies, the EM presented the CEO
with the three best offers. The CEO decided to hire a local certification body that had received its
accreditation recently and was eager to do the certification audit as soon as possible. (For more
information, see: Certification audits vs. surveillance audits in ISO 14001.)

The certification audit passed with a lot of nervousness, but the certification auditors didn’t have any
major remarks on the system and after resolving some small nonconformities, the company got the
certificate.

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Conclusion
The transition was a success and it brought many unexpected improvements to the existing
Environmental Management System. Adopting the new standard early sent a clear message to the
existing and prospective customers – that the company was taking a leading, innovative, and proactive
approach to environmental management through new management systems.

Clearly, it is better to start working on the transition sooner, rather than later, to gain early benefits of
the new standard and to improve business performance.

Sample documentation toolkit

You can download a preview of the ISO 14001:2015 Transition Toolkit. This will allow you to see a sample
of the policies and procedures required to make the transition to the ISO 14001:2015 standard and see
what changes should be made to your existing documentation.

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