Transition Auditing, Certification, and Conformity Assessment
Domain focus
This domain covers the rules for moving an ISO 14001:2004 certificate to ISO 14001:2015. It tests IAF transition guidance, audit planning, auditor competence, and certification decision-making. The key question is not whether the organization has new documents, but whether the updated EMS is implemented and effective.
Core rules
- The transition period ran for three years from publication, ending 14 September 2018. Certificates to ISO 14001:2004 were invalid after that date.
- IAF ID 10:2015 provides transition planning guidance. Certification bodies plan transition audits, which may be combined with surveillance or recertification, or conducted as a special audit.
- Audit time follows IAF MD 5; multi-site sampling follows IAF MD 1.
- A transition audit must cover all ISO 14001:2015 requirements, including the new and changed requirements: context (4.1 and 4.2), leadership (5.1), risks and opportunities (6.1), life cycle perspective (6.1.2), compliance obligations (6.1.3), documented information (7.5), outsourced process control (8.1), and evaluation of environmental performance (9.1).
- The certification body must ensure auditor competence for the new concepts, including life cycle thinking and risk-based planning. ISO/IEC 17021-1 requires competence evaluation.
- A major nonconformity must be corrected and corrective action verified before transition can be recommended.
Worked example
An organization's ISO 14001:2004 certificate expires in March 2018. It schedules a transition audit combined with its surveillance audit. The auditor checks the context analysis, interested-party register, risk and opportunity register, life cycle consideration in procurement, and evidence that top management has integrated the EMS into business processes. Procurement has no life cycle consideration, which is a nonconformity against 6.1.2. The certification body requires correction and corrective action before recommending transition. The reasoning: combining with surveillance is allowed, but the audit must still cover all new requirements with sufficient time.
Traps
- Thinking a documentation review alone proves transition; implementation evidence is required.
- Assuming a 2004 certificate stayed valid after 14 September 2018.
- Combining the audit with surveillance but failing to cover all new requirements.
- Using auditors who lack competence in life cycle and risk.
- Treating the transition audit as a gap audit rather than a conformity audit.