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:
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:
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.
Federal Environmental Agencies
State/Provincial Environmental Agencies
Municipal/Local Environmental Agencies
Global Legislative Bodies
Fire & Rescue Service
Local Government/City Councils
Your Company’s Executive Leadership Team
Local Facility Top Management
R&D staff and engineers
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.
Director of Ontario Company Sentenced to Jail Time and Fines for Offences under the Canadian Environmental Protection Act, 1999
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.
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Additional information: http://www.senado.gov.ar/parlamentario/comisiones/verExp/2505.18/S/PL.