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GHD Environment Ltd


GHD Environment Ltd (formerly CRA Europe) is an environmental, health and safety consultancy, specialising in operational regulatory compliance, property and asset management, contaminated land, management systems and corporate responsibility. GHD Environment Ltd, which is part of Gutteridge, Haskins and Davey, was established in the UK in 1995. We work closely with our colleagues globally and are able to call on the technical skills of over 8,500 staff to provide a formidable breadth of expertise. Serving an extensive client base of UK firms, we also support multinational clients operating in the UK and European markets. Our client base includes some of the biggest names in oil and gas, manufacturing, engineering, and food production. We are proud of the relationships that we build with our clients and the level of trust that they place in us.


Mr Nigel Leehane
Synergy House Unit 1, Calverton Business Park Hoyle Road
NG14 6QL

ISO Members Vote to Advance the Revision of ISO 14001

The latest draft ("CD2") of the revised ISO 14001 was circulated to ISO's members at the end of 2013, for comment and to vote on whether the work should proceed to the next stage. A substantial majority (45 votes for and 6 against) of those countries responding were in support of the working group continuing to develop a "Draft International Standard".

The latest draft ("CD2") of the revised ISO 14001 was circulated to ISO's members at the end of 2013, for comment and to vote on whether the work should proceed to the next stage. A substantial majority (45 votes for and 6 against) of those countries responding were in support of the working group continuing to develop a "Draft International Standard".

This is extremely good news, as the large majority vote means that there is widespread support for the work already done, including the new concepts and principles that have been established in CD2.

Despite this support, several hundred pages of comments have been submitted, and the working group will need to address them when it meets at the end of February. In addition to specific comments on individual clauses or terms, the respondents raised more general issues in relation to:

  The length of the draft, which is substantially more detailed than ISO 14001:2004;
  The degree of prescription in the current draft;
  Aligning the text with the latest draft of ISO 9001;
  The approach to dealing with the new concept of "risks and opportunities" and the definition of risk;
  The approach to the assessment of significant environmental aspects; and
•  The clause on the value chain.

The first two points are related; the reason that the draft text is substantially longer than its predecessor is that there is a desire to introduce more prescriptive requirements. One of the criticisms of ISO 14001:2004 is that it is too succinct. It does not provide sufficient direction, with the result that there has been too much variation in the interpretation of its requirements, leading to tremendous differences in the way it has been implemented by different organisations.

Some users of the standard have argued that this allows some organisations to develop very basic systems, which do not necessarily deliver environmental performance improvement. The greater prescription in the new draft hopefully should prevent organisations from taking this approach in future.

There is an almost constant process of review and revision of management systems standards. Currently, ISO is working on new versions of both 14001 and 9001, and is producing the first ISO version of the health and safety management system standard, OHSAS 18001. It is difficult for all the working groups, made up of volunteers, to complete their own work and also have a meaningful dialogue with the groups developing other standards.

However, consideration is given to the output of other groups, and groups will be influenced by each other's work. They will also conform to the new ISO High Level Structure and core text for management system standards, so a high degree of consistency is ensured.

Many comments were received on the related issues of how the draft text interprets the High Level Structure requirements for addressing "risks and opportunities", the definition of risk (the "effect of uncertainty") and the approach to evaluating significant environmental aspects. Many suggestions have been made for adopting new definitions of risk, including the ISO 31000 risk management standard's definition of "effect of uncertainty on objectives". Other suggestions include deleting the definition or developing something new, for environmental-related risks.

Similarly there are differing views on the interpretation of the term "risks and opportunities" and how this should be applied. Should this be confined to strategic organisational risks and opportunities or does it relate to operational level environmental risks (aspects), or a combination of these? This topic will no doubt generate substantial debate.

Finally, the Value Chain Control clause attracted a large number of comments, the majority of which related to minor terminological issues. However, there is some opposition to the use of the term "value chain", rather than "supply chain", and also to the principal of control in the value chain. It is to be hoped that "value chain" can be retained, as to many, "supply chain" implies the supply or upstream side of the relationship.

Also, many large companies can exert control over the behaviour and practices of their suppliers and customers, in addition to exerting influence. The current text does not prescribe control, but encourages organisations to consider if control would be beneficial.

Following the meeting at the end of February, CRA will publish a new series of articles on the progress made towards the publication of a Draft International Standard and any other developments. If you would like to receive updates, please sign up to our newsletter via our homepage www.cra.co.uk.


CRA's Nigel Leehane is one of the UK's technical experts appointed to the ISO working group revising 14001. Please contact him at nleehane@cra.co.uk or 01159 65670001159 656700 if you would like to know more about the changes to ISO 14001 and the implications for your organisation. Alternatively visit our Environmental Management Systems webpage http://www.cra.co.uk/service/iso-14001-ems for more information about how CRA could help with the development of a management system for your organisation.

© Faversham House Group Ltd 2020. WWT and WET News news articles may be copied or forwarded for individual use only. No other reproduction or distribution is permitted without prior written consent.

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