Interested Parties
 
Under Clause 4.2 of the 2015 Standard of ISO 14001, you are required to determine if there are individuals or organizations that could or are interested in your organization’s environmental performance and related activities.  Figuring out who your interested parties are and what they will or may want from you is a new requirement - one in which we have seen many organizations fall short of looking at the broad canopy of people and organizations that should be evaluated.
 
Here, we provide a quick summary of an assessment approach that has been well received by several registrar auditors across the globe.
 
Under the 2015 Standard an Interested Party is by definition a “person or organization that can affect, be affected by, or perceive itself to be affected by a decision or activity” by your operation.
 
Clause 4.2 specifically states that your operation seeking to obtain 14001 certification shall determine:

1. The interested parties that are relevant to the environmental management system;
2. The relevant needs and expectations (i.e. requirements) of these interested parties; and
3. Which of these needs and expectations become its compliance obligations.

 
Traditionally, many of us perceived that governmental regulators and their enforcement arms were the primary interested party of your environmental performance. This lead to understanding the laws and regulations for your jurisdiction and developing a Legal Register and list of key requirements. With the new Clause 4.2, the list of interested parties needs to cover a more expansive range of individuals and organizations. We like to break the various entities into subgroups as follows:
 

• BUSINESS AREAS – such as Customers, Investors, etc.
• REGULATING BODIES – such as Federal, State, Provincial, etc.
• COMMUNITY/SOCIAL – such as NGOs, citizen groups, neighbors, etc.
• YOUR COMPANY/ORGNAIZATION – such as employees, executive team, etc.

 
The following list and abbreviated explanations of how they may be “interested” should help in your evaluation. No list is completely comprehensive, and while this list is intended to cover a very broad range of parties, you need to ensure that you have addressed all possible interested parties for your organization.
 
BUSINESS AREAS
 
Customers

• Can dictate requirements (ISO certifications, etc.) in contracts
• May set expectations on ESH performance
• May require requirements for your suppliers
• May require you to use chemicals/processes that are not environmentally friendly

Suppliers

• May want to know if their staff could be impacted by risks on site
• Customer requirements for suppliers can create tracking and management requirements for ESH

Investors/Bankers

• Can dictate requirements (ISO certifications, etc.)
• Increased pressure for improved CSR performance, tracking, and reporting
• May request annual environmental disclosures

Insurers

• Periodically review and audit operations for compliance with legal obligations, but also to their standards for insurance coverage determination 
• Can place additional requirements upon a facility in order to obtain reasonable premiums

Trade Groups

• Requirements for participation in trade organizations
• Participation in surveys and support groups
• Influences quality standards and performance
• Influence on technology

Lobbyists/Pressure groups

• May request information for development of new legislation or standards

REGULATING BODIES
 
Federal Environmental Agencies

• A Nation’s highest-level regulating and enforcing arm
• Sets environmental legislation
• Ensures compliance to requirements
• May require periodic submittals of environmental performance
• May require permits to operate

State/Provincial Environmental Agencies

• Sets more local environmental legislation
• Ensures compliance to requirements
• May require periodic submittals of environmental performance
• May require permits to operate

Municipal/Local Environmental Agencies

• Sets yet more local environmental legislation
• Ensures compliance to requirements
• May require periodic submittals of environmental performance
• May require permits to operate

Global Legislative Bodies

• Establishes global standards and requirements that could apply
• May affect international trade and permitting

Certifying Bodies

• Standards, auditing and changes can influence business, ESH and customers’ requirements.

COMMUNITY/SOCIAL
 
Landlords/Office Park

• May establish environmental requirements for their liability protection or insurance requirements
• May request annual reports on chemical use, waste generation, etc.
• Neighboring companies could be concerned about chemical releases and impacts on them

Fire & Rescue Service

• May request annual visits and emergency response programs
• Conditions onsite impact usage of local municipal services

Local Community

• Poor management of operations could negatively impact the local community
• Support from and to the local community can affect brand, reputation and support
• Can dictate strong influences on business

Local Government/City Councils

• May establish local rules on environmental matters
• May be interested in a facility’s use of dangerous chemicals 

Environmental Groups

• May want to know what chemicals and wastes are generated and how they are disposed of
• May want to see a strong recycling program

COMPANY/ORGNAIZATION
 
Your Company’s Executive Leadership Team

• Can dictate company requirements and set overall vision and objectives
• Direct influence over policy, procedures, new initiatives, culture and resources

Local Facility Top Management

• Can set local requirements on environmental objectives based on company policy, directives, vision
• May be concerned over environmental performance for a variety of factors (community, customer requirements, etc.)
• Direct influence over policy, procedures, new initiatives, culture, and resources

Employees

• May be concerned about environmental impacts from the company
• Often wants to see a strong recycling program

R&D staff and engineers

• May be concerned about new environmental legislation that could impact product design, use, and disposal
• May want to know or have input from the environmental team on packaging

Unions

• May want to know about environmental impacts in their community from the facility

Contractors/Vendors

• Often less interested in a facility’s performance given their desires to obtain business from your operation, but could be interested in how they can operate on your site in an environmentally safe manner

Agency workers

• Often have similar concerns as direct employees

HR Department

• Environmental performance beginning to become an employee retention issue; HR staff may want to know about the facility’s environmental policies and performance for employee recruitment and engagement.

We have identified and summarized some two dozen various groups of individuals or organizations that could have an interest in or be affected by your facility’s environmental performance. Their interest in your management system and the site’s performance could be well beyond what we have listed here, but as you can see, the possible list of parties is much bigger than what we had to grapple with in the past ISO standard.
 
Each and every one of these parties could create needs and expectations from your environmental department and associated management system, and those needs or expectations can then become environmental obligations you are now required to comply with. Many of the entities in our list will often require an annual reporting or submittal of performance or some summary of your facility’s environmental performance. This may be as simple as an annul report, or as complicated as a 100-point questionnaire to be completed on a global platform such as from the CDP, etc.
 
For each party you should outline in correct detail what those parties need and how you will meet those obligations.  Add each requirement into your overall list of environmental obligations as required under Clause 6.1.3 Compliance Obligations. 

Note that how you meet your interested party’s needs also has to be considered under Clause 9.1.1 Monitoring, Measurement, Analysis and Evaluation if they address requirements of tracking and monitoring of environmental performance.
 
Lastly, you need to address how and if your failure to do any of these activities could pose a risk to your organization, or if there are any good opportunities for improvement (Clauses 6.1.1 and 10.3).
 
As you can see, the work to address one clause such as Interested Parties influences and needs to be further considered or addressed in several other clauses of the Standard.

Richard DiNitto is a founding director of The Isosceles Group, with over 30 years of professional experience in environmental health and safety consulting and facility management across the globe. He has been involved with the ISO certification and recertification for several facilities for ISO 14001 both in the US, Europe and Mexico for more than 10 years. Mr. DiNitto also developed the firm’s program and international team of regulatory analysts to develop international regulatory compliance audit protocols and regulatory updates. He currently assists multi-international firms with their environmental health and safety management programs and onsite EHS staff and compliance.

On August 21, 2018, Collingwood Prime Realty Holdings Corp. and its director were sentenced in the Ontario Court of Justice for offences under the Canadian Environmental Protection Act, 1999.  The sentence resulted from an investigation which uncovered two electrical transformers and eight electrical capacitors that contained impermissible PCB levels.  The equipment had not been sent for destruction to an authorized facility.  The court sentenced the director to a 45-day jail term due to the failure to comply with an environmental protection compliance order. The Court also sentenced the corporation and director to pay a combined penalty of $420,000 to the Federal Environmental Damages Fund.
 
Additional information: https://www.canada.ca/en/environment-climate-change/services/environmental-enforcement/notifications/director-ontario-company-sentenced-jail-time-fined-offences-canadian-environmental-protection-act-1999.html. 

Senate Bill No. 2505/2018 established the Electronic Waste Treatment Program. The purpose of Bill’s requirements is to provide basic knowledge to the population on the importance of the treatment, recovery, reuse and recycling of Electrical and Electronic Equipment (EEE) and Waste Electrical and Electronic Devices (WEEE). The Bill also seeks to enhance awareness on the impact of these materials on the ecosystem.
 
Additional information: http://www.senado.gov.ar/parlamentario/comisiones/verExp/2505.18/S/PL.