Improvement and Environmental Management System Changes (ISO 14001:2015 transition)
Domain focus
This domain tests clause 10 and the management of EMS changes. The 2015 revision removed preventive action as a separate clause, embedded risk-based thinking in planning and corrective action, and made changes to the EMS themselves subject to control and review.
Core rules
- 10.1 requires determining opportunities for improvement to meet intended outcomes.
- 10.2 nonconformity and corrective action: react to the nonconformity, correct it, deal with consequences, evaluate the need to eliminate the cause, implement action, review effectiveness, update risks and opportunities under 6.1.1, and make changes to the EMS if necessary. Retain documented information on the nonconformity, actions taken, and results.
- 10.3 continual improvement: continually improve the suitability, adequacy, and effectiveness of the EMS to enhance environmental performance. This is broader than correcting nonconformities.
- Change control: 8.1 requires control of planned changes and review of the consequences of unintended changes, with action to mitigate adverse effects where necessary.
- Preventive action: not deleted. It is integrated into 6.1 risk and opportunity planning and 10.2 corrective action, which must prevent recurrence.
Worked example
An internal audit finds a missing spill kit in a solvent store. The organization restocks the kit, which is correction. It then asks why the kit was missing and finds that the weekly inspection checklist omitted the store. It adds the store to the checklist, assigns responsibility, trains staff, updates the risk register, and checks after three months that no gaps recur. This is corrective action. The 2015 standard explicitly requires considering updates to risks and opportunities and changes to the EMS. If the organization only restocks, it fails 10.2.
Traps
- Confusing correction with corrective action.
- Forgetting that 10.2 requires reviewing whether risks and opportunities need updating and whether EMS changes are needed.
- Claiming preventive action was removed by the 2015 revision.
- Treating continual improvement as any administrative change; it must enhance environmental performance.
- Overlooking 8.1 when planned changes alter environmental aspects or controls.