6.1 Actions to Address Risks and Opportunities [ISO 14001]

6.1.1 General

ISO 14001:2015 requires organisations to consider risks and opportunities in relation to internal and external issues, environmental aspects and compliance obligations which themselves may be a source of risk or opportunity.

Section 6.1 requires an organization to maintain documented information of the process(es) needed in 6.1.1 to 6.1.4, to the extent necessary to have confidence they are carried out as planned.

Contents

Documentation

Documentation for clause 6.1 identifies, outlines, and acknowledges the company's environmental risks and any opportunities that it may encounter.

These would include any abnormal risks and all and any emergency situations that may arise.

It also needs to show any opportunities the company may face to make any positive environmental changes or impacts.

The ISO 14001 standard does not prescribe a particular risk process or methodology to be documented; however, the onus is placed on the company to demonstrate a sound risk-based system is being followed.

The system the company follows should be easily explainable.

Approach

  • The approach should be evidence-based, auditable documentation provided along with a sound and viable operational plan
  • Link the policy to the various ISO 14001 clauses to assist in the analysis when needed
  • Review any existing environmental aspect evaluation processes so that an identification of risks and opportunities is undertaken for each environmental aspect and related compliance obligation
  • Determine the environmental aspects of activities, products and services, and their environmental impacts, considering a life cycle perspective
  • Ensure the process for determining which interested party needs and expectations become compliance obligations is based on risks and opportunities
  • Identify risks and opportunities that need to be addressed in relation to internal and external issues
  • Establish environmental objectives at relevant functions and levels

Undertake a SWOT analysis as part of your organisation’s business strategy to identify the external risks and opportunities, and plan actions to address them. Formal business risk assessment performed by your organization should take into consideration its context, associated risk and opportunities and mitigation plan.

Using the process approach, identify sources of input, activities, output, receiver of output, performance indicators to control and monitor processes, the risks and opportunities associated with them and action plan to address them.

Outcomes and Options Include

  • Avoiding the risk
  • Taking risk in order to pursue an opportunity
  • Eliminating the risk source
  • Changing the likelihood or consequences
  • Sharing the risk with stakeholder
  • Retaining risk by informed decision

Wind turbine Environmental Aspects

6.1.2 Environmental Aspects

The organization has to determine the environmental aspects, and the impacts of your activities, products and services that are under its control and influence.

Your organization should establish criteria to determine which of these aspects have or can have a significant environmental impact.

  • Environmental Aspect – ‘is an element of your organization’s activities, products or services that interacts or can interact with the environment’.
  • Environmental Impact – ‘changes to the environment, whether adverse or beneficial, wholly or partly resulting from your organization’s environmental aspects’.
  • Significant environmental aspects – can result in risks and opportunities with associated adverse or beneficial impacts. Objective evidence must contain established criteria for evaluating significance of aspects (i.e., quantitative process or qualitative procedure).

Categories of Environmental Aspects

Environmental aspects should be categorised as:

  • Normal – environmental aspects are those encountered as part of routine operations.
  • Abnormal – environmental aspects are from activities not normally encountered as part of day-to-day running of the business e.g., night operations or unscheduled maintenance of broken machinery.
  • Emergency – environmental aspects are encountered in emergency situations such as equipment failure, extreme weather or fire.

An initial review of site information and baseline data from annual running costs and the quantities of energy use, water use, the waste produced and the raw materials used will help you to prepare a list of environmental aspects for your company.

Therefore, you need to think of environmental aspects at each stage of the ‘lifecycle’. It requires careful consideration of the lifecycle stages whose environmental aspects can be controlled or influenced.

Consider aspects associated with:

  • Natural resources use (mining, water withdrawal)
  • Purchased raw materials
  • Transportation
  • Manufacturing, services, other activities
  • By-products: air, waste and waste emissions
  • Transportation of products
  • Use of products and services
  • End of life issues – recycling and disposal

In laymen’s terms, environmental aspects cause; or have the potential to cause, an environmental impact.

Examples of Environmental Aspects

  • Emissions to air via smoke or fumes
  • Waste water discharge
  • The potential for accidental chemical spill
  • The generation of waste and disposal of waste
  • The use of resources, including water and energy
  • The use of recycled materials
  • Noise and vibration

A cause-and-effect relationship exists between environmental aspects and environmental impacts, respectively. For instance, an environmental aspect, or cause, can be the emission of volatile organic compounds. The environmental impact, or effect; is ozone depletion.

Five Actions for Compliance

To comply with ISO 14001 Section 6.1.2, the following five actions should be undertaken:

  • Identify all of your organization’s activities, products and services
  • Identify the environmental aspects of all activities, products and services that can be controlled or influenced
  • Identify the environmental impact(s) of each aspect
  • Establish and maintain a procedure or method to identify any new or modified environment aspect or impact
  • Identify the most significant environmental impacts

The identification of environmental aspects will form the foundation of your environmental management system. The operational aspects that have significant impacts on the environment should become the basis for your organization to develop appropriate objectives and targets; therefore, you should be thorough when completing this step.

Environmental Impacts – Objective Evidence Matrix Example


Aspect Impact Activities Objective Target

Energy usage

Low volume usage

Site-wide

Ensure no increase

No increase above 50 kW/PA

Use of VOCs

High volume usage

Fabrication

Reduce volume of VOC usage by using alternatives

Reduction of VOCs use by 50%

Contaminated scrap

High volume

Fabrication

Segregate contaminants from other scrap

Reduce by 20%

Exhaust emissions

Co2 emissions

Delivery/Transport

Drivers to turn off engine when static

Reduce by 10%

Objective evidence must contain established criteria for evaluating the significance of environmental aspects; perhaps using an Excel workbook, ideally with formulae for calculating significance.

Compliance

6.1.3 Compliance Obligations

Compliance obligations will arise from mandatory requirements, and these include for example, applicable laws that require permits and regulations that apply to the environmental aspects of your business’s activities, products and services, and their associated environmental impact.

While voluntary commitments might arise from organizational and industry standards, supply chain relationships, commitments established in contracts and product specifications, principles of good governance, community relations, and ethical standards. Both voluntary and mandatory compliance obligations can result in risks and opportunities to the way you do business.

Documented information could be a list or matrix of compliance obligations:

Environmental Aspect Compliance Obligation Risks Opportunities
Mandatory Voluntary

Using f-gases in air conditioning units

The Fluorinated Greenhouse Gases Regulations 2009

Annual sustainability and corporate responsibility reporting

Compliance with emission limits

Restrict hazardous substances in specifications

Disposal of waste batteries

Waste Batteries and Accumulators Regulations 2009

Adopt a community environmental recycling project

Time and resources

Positive publicity

Generation of waste

Control of Pollution Act (COPA) 1974

Agreement to meet a packaging reduction target

Licence/permit compliance and reporting

Increased revenue from waste recovery and recycling approaches

In order to document your organization’s compliance obligations, you could use an Excel workbook comprising an indexed list of relevant legal requirements, and other obligations.

Other obligations might include standards and procedures in connection with operational tasks and associated hazards by referencing the minimum acceptable legal, industry standards and technical specifications against the associated equipment and operating routines at your facility.

Information in the compliance obligations register for each requirement includes but is not limited to:

  • Interested parties and their environmental needs and expectations
  • Title and description of the related legal requirement
  • Description of how the legal requirement applies and whether relevant licenses or approvals are required
  • The related risks, opportunities and mitigation actions
  • The title and description of supporting documents that demonstrate compliance
  • How compliance is verified

The compliance obligations register must be reviewed and updated for adequacy, both for new regulations and updated regulations, on a quarterly basis and communicated to relevant staff whose responsibilities or actions can affect compliance.

Planning action

6.1.4 Planning Action

Clause 6.1.4 of ISO 14001:2015 requires an organisation to take actions to address its significant aspects, compliance obligations and risks and opportunities. The standard requires a planned approach with respect to the actions that arise from Clause 6.1.1, 6.1.2, and 6.1.3, with the environmental management actions being integrated into other processes that exist within the business.

The actions planned must include the establishment of environmental objectives, improving existing controls, e.g., procurement, finance or design departments, establishing or expanding monitoring regimes and methods; or incorporating the actions into a new EMS specific process, e.g., new operational controls (Clause 8.1) or new emergency preparedness routines (Clause 8.2).

The ISO 14001 standard states that an organization should:

  • Establish
  • Implement
  • Maintain

the processes that are required to address the planning section needs fully.

When the Environmental Manager plans the EMS, they need to carefully consider the organization's context according to section 4.1 and the expectations and needs of all interested parties according to section 4.2, including the scope of the EMS.

Things that need to be considered in respect to the abovementioned elements are risk and opportunity. Furthermore, all environmental, legal, and regulatory issues need to be considered.

The goal is to ensure the EMS can reach its intended objectives and outcomes and avoid any external factors that can prevent it from becoming a reality. Lastly, the aim is that continual improvement must be achieved.

The organization is required to be able to forecast and determine any emergency situations that may occur and what their environmental impact may be. Critical to this are the related documented procedures regarding risk mitigation and control.

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Updated: 24th October 2021
Author: Richard Keen

Richard Keen

Richard Keen

Richard is our Compliance Director, responsible for content & product development.
But most importantly he is ISO's biggest fanboy and a true evangelist of the standards.
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