By Andrew H. Perellis and Mike Radcliffe

Seyfarth Synopsis:  This blog welcomes Mike Radcliffe, for our guest author’s thoughts on the up and coming deadline for organizations to come into compliance with the new ISO 14001:2015 environmental management system (EMS) standard.

The new ISO standard brings significant change that will require considerable time and thought to implement. Due to the timing, the strategy should focus on implementing the EMS to address the greatest “gaps” and developing the “hard proof” of its effectiveness within your organization.

While it’s not too late to start with an ISO 14001:2015 installation, there should be little delay.  The deadline for recertification of your ISO 14001 EMS is September 15, 2018. After that, certificates issued under the ISO 14001:2004 standard will no longer be valid.

Some companies have the time and expertise to implement needed changes internally.  However, many companies will need to rely on outside assistance. Knowledgeable consultants are busy and will increasingly be in tight supply.  Radcliffe , an independent consultant already assisting several companies with the recertification process, cautions that the project lifecycle for a well-crafted EMS can require up to a year from design to full implementation. Not all of this time is spent developing and writing procedures and work instructions.

In fact, a majority of the time will involve collaboration between the consultant and the company’s internal staff to implement the EMS, by testing the procedures, developing proof that the EMS is functioning, and confirming that the EMS will be able to fulfill its strategic purpose. In addition, under the new ISO 14001:2015 requirements, the organization needs to formulate an approach for including its interested parties and stakeholders (e.g., suppliers) in its contextual analysis (e.g., how, where and with whom does it operate) and in its life cycle thinking. Such strategic thinking will obviously be impaired by tight deadlines.

Other significant changes to the EMS also require advance planning and thoughtful implementation. According to Radcliffe, some of the thematic differences between the two standards are:

  1. EMS aligned with the organization’s strategic direction.
  2. Top management more engaged and subject to nine specific accountabilities.
  3. Consideration of strategic threats and opportunities.
  4. Focus on Life Cycle thinking.
  5. Integrating EMS functionality into business operations.

In sum, the new ISO standard is a significant change that will require time and thought to implement. Companies are urged to look at their EMS systems soon, and bring them into compliance.

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the Seyfarth Environmental Compliance, Enforcement & Permitting Team.  Information on Mike Radcliffe can be found on his LinkedIn page, and he can be contacted at