Preparing for transition to ISO 14001:2015 – determining context

In the second of a series of articles SLR's Nigel Leehane has written, he will be helping organisations understand the implications of transitioning to ISO 14001:2015. His article explores the new requirement for Context (including the needs and expectations of interested parties), and how to address it. 

What is "context"?

The clause on context is brief. In essence it establishes a requirement to consider internal and external factors influencing an organisation’s ability to achieve its vision and mission and the aims of its EMS. The outcome from this process provides the basis for setting the scope of the EMS and designing the system. The needs and expectations of interested parties (or stakeholders) relates to both internal and external stakeholders, and is a fundamental element of an organisation’s context. This is a high-level, strategic exercise, to provide an overview of key issues for the business, very much entwined with its overall strategy. Effective assessment of context can be a useful tool in engaging senior management, convincing them of the value to the business of robust environmental management and relevant environmental initiatives. 

ISO 14001:2015 provides the following explanation of context and stakeholder expectations:

  • Environmental conditions includes sensitive environments that the organisation could impact, and environmental factors that could impact on the organisation
  • External context includes cultural, social, political, legal and economic issues
  • Internal characteristics include activities, products and services, and also culture, organisational capabilities and goals
  • Stakeholders include customers, communities, suppliers, regulators, non-governmental organisations, investors and employees.

Examples of context and the implications for the EMS

The following examples illustrate how different outcomes from a review of context can shape the scope and content of an EMS:

Example - A company providing engineering maintenance services to global oil and gas exploration clients

Issues from context:

  • Its clients will be important stakeholders, no doubt imposing contract conditions for environmental management of maintenance work on their sites
  • Many work sites will be in offshore locations and other sensitive environments
  • Changing weather patterns may impact on logistics support services
  • External factors related to different jurisdictions will influence compliance requirements for operations and potentially for the import and export of materials

Implications for the scope and content of the EMS:

  • The scope will take account of overseas locations and fieldwork activities, and make allowance for interfacing with customer management systems
  • The EMS will include processes for risk assessment and site specific environmental management plans, and will make provision for communications with remote operations and field staff.

Example - A UK food manufacturer supplying retailers

Issues from context:

  • Again, its clients will be important stakeholders, specifying the characteristics of the products (food quality, packaging, etc.)
  • Large food production facilities will be heavily regulated
  • External environmental factors (such as pressure on ecosystem services) may have implications for availability and cost of raw materials
  • Cultural factors including workforce language barriers and customs may influence communications and training needs
  • The company’s business strategy is to differentiate itself on cost, so operational efficiencies will be important

Implications for the scope and content of the EMS:

  • The scope of the EMS may be focussed on manufacturing operations, but will also need to extend control to the characteristics of raw materials, subject to the degree of influence
  • Some documentation may need to be in a variety of languages and induction training will need to reflect worker languages and customs
  • Operational processes will need to be flexible to meet different customer requirements and also minimise waste from changeovers
  • There will be a focus on monitoring energy, resource consumption and waste reduction.

How to tackle this task?

Frustratingly, ISO 14001 and 14004 provide little guidance in how to determine context, other than explaining what is meant by the concept. However, given that this is a high-level issue, organisations can apply the same techniques they would use for any other type of strategic assessment, including brainstorming, SWOT and PESTEL analyses. Some form of stakeholder engagement is needed, and the scale and complexity of this should reflect the size of the organisation and its relationships with interested parties. Interactions could range from conversations with key customers or suppliers, to detailed materiality studies (potentially undertaken as scoping studies for corporate reporting). There is no requirement to document the outcome of the process to determine context, but in reality some form of report or minutes will be helpful.

Horizon-scanning is an important element of maintaining an understanding of context. Organisations need to keep track of potential implications of forthcoming developments, for example in legislation and policy initiatives, such as the growing emphasis on the circular economy. Brexit also will have potential implications for trade and customer/supplier relationships.

Further information

I’ll be participating a BSI ISO 14001 webinar on context in late September. If you are interested, details will be available shortly at https://www.bsigroup.com/en-GB/iso-14001-environmental-management/ISO-14001-revision-new/:

If you would like more information on the transition and support available, please get in touch by contacting Nigel at nleehane@slrconsulting.com. The next article in this series will address leadership.