Organizations operating EMSs (Environmental Management Systems) faced significant changes mandated by the release of the updated ISO 14001:2015 standard. The latest version of the standard set out significant requirements for how your organization handles outsourced suppliers and services, and some of those requirements aren’t obvious at first glance. The new standard’s language uses “outsourced suppliers” to refer to any and all third parties that have contracts to perform critical services or supply vital parts. These supplier organizations are usually operating outside your facilities, but this is not an actual requirement for the application of ISO 14001. Let’s look in greater depth at the new obligations imposed by ISO 14001:2015 and the actions you might have to take to keep your EMS compliant with the regulation.
Unpacking the Changes
In the barest terms, the relevant section of 14001:2015 obliges an organization to set environmental requirements for operational planning and control in all cases where they impact products and services. This seems very close to the way the older 14001:2004 standard treated outsourced suppliers, but there are significant changes to be found in the material contained in Appendix A. The appendix goes into much greater detail about the organization’s responsibility to exert control over external suppliers based on several different factors. Examples include technical competence, the criticality of the products and/or services being supplied, the ease of verifying compliance, and the way the organization’s ordinary purchasing process might address these supply needs normally. While Appendix A details several variations in control based on how these factors interact in specific cases, all cases share a common theme of responsibility. Your organization is always fully responsible for the environmental performance of any and all outsourced suppliers it engages in order to deliver products and/or services.
Nailing Down the Basics
Our last article on moving toward ISO 14001 compliance concentrated on the environmental benefits and organizational advantages offered by working with ISO 14001-certified suppliers. The ISO 14001:2015 standard does not alter the benefits available to your organization, but it obliges you to answer some additional questions:
- How likely is it that your suppliers are capable of delivering on environmental performance indicators?
- If you work with a non-certified supplier, do they have an environmental policy of their own? How does their environmental policy interact with your organization’s?
- Do your suppliers fully understand the legislation that covers your product and the steps required to deliver it?
- Do your suppliers perform internal audits? Are the results of audits available to your organization?
- Can your suppliers show evidence of risk-based thinking and environmental impact mitigation?
What can your organization do to unlock the full benefits of compliance with ISO 14001:2015 compliance among your suppliers? There are a few different steps you can take to verify your suppliers’ abilities to comply:
- Mandate detailed and specific key performance indicators on which you need regular reports from your suppliers.
- Encourage suppliers to put environmental criteria at the top of their priorities when making purchase decisions.
- Request legislation logs from your suppliers to verify their understanding of and compliance with all relevant environmental legislation.
- Request environmental risk identification, risk assessments, and suggestions for environmental improvements.
- Require your suppliers to verify their commitment to properly recording and reporting environmental performance. Your suppliers need established policies for reporting and dealing with environmental emergencies and other incidents. Authority notification, containment, and mitigation all need to be addressed.
Your organization needs to have a formalized schedule for auditing and reviewing the environmental performance of your outsourced suppliers. This gives you the opportunity to assess that performance and take corrective action when and if it becomes necessary. Regular auditing is a simple and effective way of ensuring ISO 14001:2015 compliance among outsourced suppliers. All of your organization’s environmental expectations should be incorporated, in as much detail as possible, into the contracts you sign with outsourced suppliers.
If your organization has any questions about ISO 14001, contact us here American Quality Management to speak to a consultant today.