By James Clayton
In my previous blog on management system integration I highlighted the planned changes to the environmental management system standard, ISO 14001:2015, and the development of the occupational health and safety management system standard ISO 45001, the replacement for BS OHSAS 18001. Both ISO 14001:2015 and ISO 45001 will follow a core structure known as the High Level Structure (HLS) and have common text and terminology. Each management system standard will then add additional “discipline-specific” requirements as necessary.
A second committee draft (CD2) of ISO 45001 was published in March and we can start to see the specific detail that it is likely to contain when it is published later in 2016. The International Accreditation Forum (IAF), which operates a worldwide mutual recognition arrangement among Accreditation Bodies (ABs), won’t be issuing transition planning guidance for ISO 45001 for some time. However, it is available for ISO 14001:2015 and I’d like to outline some guidance for organisations that already have certification to either ISO 14001:2004 or BS OHSAS 18001 and will be looking to transition to the new standards.
The IAF have agreed a three-year transition period from the publication date of ISO 14001:2015 (and it is likely that most organisations that currently have certification to BS OHSAS 18001 will also want to transition to ISO 45001). This means that ISO 14001:2004 certifications will not be valid after three years from the publication of ISO 14001:2015.
For any organisation the degree of change necessary will be dependent upon the maturity and effectiveness of the current management system, organisational structure and practices, therefore the IAF recommend an impact analysis/gap assessment in order to identify realistic resource and time implications. Whilst this may seem premature for ISO 45001 a gap analysis now against CD2, which is updated as it moves through the draft and final draft stages, may be prudent.
Organisations are recommended to take the following actions:
For ISO 14001:2015 it is likely that most CBs will want to engage with their clients to define a certification transition plan. Whilst CBs are free to define their own policies regarding transition, few are likely to be prepared to leave the transition process too close to Autumn 2018, when certification against the 2004 standard will be invalid.
CBs can conduct transition activities during a routine surveillance, recertification audit or a ‘special’ (additional) audit. Where transition audits are carried out in conjunction with scheduled surveillance or recertification (i.e. progressive or staged approach), additional time is likely to be required to ensure that all activities are covered for the existing and new standards.
You can expect that your CB will clearly identify, and raise as documented findings, all issues that require action from your organisation for conformity with the new standards. Only when all identified outstanding issues have been appropriately addressed and the effectiveness of the management system demonstrated, can auditors recommend certification to the new standards. Records will need to be available to demonstrate that all prior transition audit findings have been evaluated for corrective action and conformity before any recommendation for approval to ISO 14001:2015 can be made.
If your organisation is planning to transition to ISO 14001:2015 and/or ISO 45001 the most convenient and cost-effective stage to do this at will be re-certification. Whilst CBs cannot raise non-conformances against the new standards until a formal transition process is started, there is no reason why they cannot raise observations against draft versions of the new standards and it may be worth discussing this with your CB to gain further insight into your organisation’s state of readiness for the new standards.
However you plan to approach transition, it is important not to underestimate the changes that are in the new standards and implement an effective transition plan in consultation with your CB.
James Clayton CMIOSH CEnv is an independent consultant, auditor and trainer and founder of EHS Rated.com, the environment, health and safety marketplace.
