Management system guidance
6.1 Actions to Address Risks and Opportunities
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6.1.2 Environmental aspects
Within the scope of your environmental management system, your organization must identify the environmental aspects of its activities, products and services, both those it controls directly and those it can only influence, together with the environmental impacts each aspect causes. This has to be done from a life cycle perspective. An aspect is the cause (e.g. a solvent emission, a wastewater discharge, electricity consumption) and the impact is the effect on the environment (e.g. air pollution, water contamination, climate change). Your organization is responsible for:
- Identifying the environmental aspects of its activities, products and services, and their associated environmental impacts;
- Considering the life cycle perspective, i.e. thinking about the aspects and impacts at each life cycle stage that applies, such as:
- Acquisition of raw materials and environmental impacts within the supply chain;
- Design of products, services and processes;
- Production, transportation and delivery;
- Environmental impacts associated with product use;
- End-of-life treatment and final disposal.
- Identifying potential emergency situations, including those that could have an environmental impact (see 8.2 Emergency preparedness and response);
- Taking into account normal and abnormal operating conditions, change (such as planned developments, new sites, and new or changed activities, products and services - see 6.3 Planning of changes) and potential emergency situations;
- Applying established criteria to decide which aspects have, or could have, a significant environmental impact (significant environmental aspects);
- Communicating the significant environmental aspects across the relevant levels and functions of the organization;
- Making documented information available on the environmental aspects and impacts, the significance criteria, and the significant environmental aspects.
What changed in ISO 14001:2026
The core requirement is the same as in ISO 14001:2015, but there are some important changes. The determination of potential emergency situations has moved here from the old 6.1.1, so your aspects review is now the place where emergencies are identified; clause 8.2 then requires processes to respond to the emergencies determined in 6.1.2. The conditions to be taken into account have been restructured into three items (normal and abnormal conditions, change, and potential emergency situations), so normal operating conditions are now named explicitly; the new life cycle note now names the life cycle stages, and a new note confirms that significant environmental aspects can give rise to risks and opportunities with adverse or beneficial effects. Those risks and opportunities are dealt with in 6.1.4 Risks and opportunities. Documented information is now required to be "available" rather than "maintained".
The identification of environmental aspects will form the foundation of your management system. The aspects that have significant impacts on the environment will become the basis of your organization’s environmental objectives and operational controls; therefore, you will want to be thorough in completing this step.
Developing a list of the organization’s activities, products, and services can be a difficult task. The activity, product, or service should be small enough to be understood, but large enough to be analyzed. You do not need to assess every product, component or raw material on its own; activities, products and services with common characteristics can be grouped together.
Identification of environmental aspects
Using the environmental aspect and impact register, identify all raw materials, chemicals and utilities that are used as process inputs and all outputs such as products, services and by-products. Outputs are considered as products, the waste produced, levels of recycled materials, quantities of water discharge and air emissions for each process or activity.
Following the identification of environmental aspects, their impacts on the environment are evaluated and an impact rating should be assigned. All of the organization’s activities should be considered when identifying actual and potential environmental aspects and impacts whilst taking account of:
- Past environmental incidents;
- Air emissions to atmosphere;
- Water usage and discharges to surface water groundwater and sewers;
- Land contamination caused by spillages, etc.;
- The production, re-use, recycling and disposal of controlled and special wastes;
- The storage and management of materials;
- Activities upon local ecology and biodiversity of operations, sites and premises;
- Energy emitted, such as environmental noise, vibration, heat, light and radiation;
- Energy use and management;
- Use of transport and vehicles;
- Use of natural resources, land, and marine or coastal areas;
- Raw materials and packaging;
- Office activities;
- Landscaping and infrastructure;
- The environmental performance and practices of external providers;
- Other relevant issues such as odors, particulates, lighting and pests.
Normal, abnormal and emergency conditions, and change
When identifying inputs and outputs, consider all modes of operation. Start-up, shutdown, maintenance and breakdown conditions can introduce additional environmental aspects and impacts into your processes, and adverse weather or other environmental conditions can increase emissions or releases. Look ahead as well: planned developments, new sites, new or modified products and changes to processes should be assessed before they are introduced, not after.
For potential emergency situations (e.g. fire, chemical spill, flooding, severe weather), think about:
- The hazards present on site, such as flammable liquids, bulk storage tanks and compressed gases;
- The most likely type and scale of emergency, informed by past incidents and near misses;
- Emergencies that could start at a neighboring facility, road or railway and affect your site.
Record emergency-related aspects in the same register so that they feed directly into your emergency response planning under 8.2. Because of their potential severity, emergency aspects frequently turn out to be significant.
Assessment of environmental impacts
Once the impacts have been identified ensure they are prioritized in terms of their environmental impact to assist in using them for setting environmental objectives and for identifying operational control procedures. Ensure each aspect identified is assigned a significance rating to indicate the relative importance of its related environmental impact.
The significance rating is used to define those impacts which are to be controlled through environmental objectives, or by the implementation of operational control procedures.
The assessment of the severity of an environmental impact drives management attention and supports planning for mitigation. A qualitative risk assessment scheme consisting of qualitative probability and impact scales should be undertaken to ensure detailed understanding of the effects of each impact. The Environment and Sustainability Manager should engage with Process Owners to:
- Identify the control measures already applied to each significant impact i.e. existing control measures. These may be pro-active (reducing the probability) or reactive (reducing the impact);
- Rank the probability of each impact occurring, after taking into account the actual effectiveness of the existing control measures;
- Enter the existing control measures and the associated current impact scores;
- Undertake a risk assessment to provide more detailed understanding of the impact’s consequences;
- Set environmental objectives for achieving impact mitigation.
Using the ‘significance determination’, evaluate each identified aspect to determine whether it is significant. The environmental aspects should be considered to be significant if the aspect has an impact on the environment and meets the impact scoring criteria for implementing mitigation. Environmental criteria (e.g. scale, severity, duration and frequency of the impact) should always be the primary criteria. Other criteria, such as legal requirements or the concerns of interested parties, can raise an aspect to significant, but should never be used to downgrade an aspect that is significant on environmental grounds. Whatever method you choose, it should give consistent results when different people apply it.
- All aspects which elicit concerns of interested parties and our organization are regarded as significant, if the necessary control measures have not been implemented;
- All aspects which are subject to environmental legislation are regarded as significant, and therefore noted as having a high impact/risk, if there is a breach or potential breach of legislation;
- All aspects where insufficient information is available to make a reasoned judgement are regarded as significant until further information is available.
Probability or likelihood estimations should be established giving due consideration to the effectiveness of existing control measures. Consequence criteria should consider the severity, extent and duration of environmental harm, along with legal and regulatory compliance, reputation impact, potential financial loss and management time and effort.
Mitigating environmental impacts
Impact treatment involves identifying the options for treating each impact, evaluating those options, assigning accountability (for Very High, High and Moderate impacts) and taking relevant action. Actions on significant aspects are planned under 6.1.5 Planning action. The following options are available for treating impacts and may be applied individually or in combination.
For each impact, the process owner should establish an appropriate level of treatment. Control measures in addition to those already existing may be needed to achieve this level of mitigation in order to develop a satisfactory response to each impact in order to:
- Identify a response strategy to treat, terminate, tolerate or transfer the impact;
- Identify response actions to improve control measures as required. These will be SMART;
- Identify a response action owner for each action and confirm with them that they accept accountability for implementing the action within the time allowed.
The process owner should be responsible for the development of the response. When a response action is completed, the impact should be reassessed to reflect any newly introduced control measures.
Monitoring and review
Continuous systematic and formal monitoring of implementation of the environmental aspect and impact process and outputs will take place against appropriate performance indicators to ensure process compliance and effectiveness. Monitoring may take a variety of forms and range from self-assessment and internal audits to detailed reviews by independent external experts.
Regular reviews are essential to ensure that aspects and impacts are being appropriately managed, and that the relevant data about those aspects and impacts remains accurate and reliable. What is significant can change over time, so the register should also be reviewed whenever there is a change to activities, products, services or environmental conditions. The Environment and Sustainability Manager should on a regular basis:
- Engage with Process Owners to ensure that the current and forecast impact severities reflect the actual effectiveness of the existing controls and the anticipated effectiveness of the response plans, and that response plans and existing controls are up-to-date;
- Challenge the continued relevance of aspects and impacts and the adequacy of the control measures and response actions;
- Review and formally issue approval of the current Environmental Aspect & Impact Register enabling it to be used for reporting;
- In the event that they will not approve (part of) the completed Environmental Aspect and Impact Register, e.g. due to the inadequacy of control measures and response actions, they will agree with the relevant process owner those additional response actions necessary, prior to approval.
Reporting
Regular reports are necessary to inform and provide assurance to Top management and other key interested parties, that impacts are being appropriately managed. Reporting must be based on current data captured in the Environmental Aspect and Impact Register, which must be updated and reviewed in good time for the next reporting cycle.
On occasion, it may be appropriate to escalate an aspect or impact to ensure it is assessed and/or managed by the person or party best placed to do so (able and with appropriate authority). For example, where a more substantial or coordinated response is required than the current process owner can authorize or implement will justify higher level assessment and/or management. The Environment and Sustainability Manager should:
- Escalate through established lines of management accountability all aspects and impacts that may require mitigation. This may take place during formal reviews, or through other simple mechanisms at management meetings;
- Issue reports in accordance with requirements;
- Provide key information such as statistical data on numbers of active impacts, unassessed aspects, overdue actions, and others as appropriate.
Environmental impact training
To ensure that adequate impact management competency levels are achieved and maintained, your organization should provide regular training in the aspect and impact management process and its application in the organization.
- Specific impact management training sessions will be held on an annual basis, aimed at providing an overview of the management framework;
- The training will be facilitated by the Environment & Sustainability Manager. Additional ad-hoc training will be provided as required;
- Instruments providing training on appropriate controls include job descriptions, inductions, policies, procedures, terms of reference, charters, performance planning and review programs, contracts and delegations.
Communication
ISO 14001:2026 requires significant environmental aspects to be communicated among the various levels and functions of the organization, as appropriate. Communication and consultation are important elements in each step of your organization’s environmental aspect and impact management process. Effective communication is essential to ensure that those responsible for implementing control, and those with a vested interest, understand the basis on which decisions are made and why particular actions are required. Your communication approach should recognize the need to promote environmental aspect and impact management concepts across all management teams and staff (see 7.4.2 Internal communication).
You should seek and record evidence that your organization has a defined method for identifying its environmental aspects and impacts that covers controlled and influenced aspects across the life cycle, abnormal conditions, planned changes and potential emergency situations. Check that significance criteria are documented, are primarily environmental and are applied consistently, and that the aspect register, criteria and list of significant aspects are available and current. Confirm that significant aspects have been communicated to relevant functions, that emergency-related aspects link through to 8.2 arrangements, and that significant aspects feed into risks and opportunities (6.1.4), planned actions (6.1.5), objectives (6.2.1) and operational controls (8.1).
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