It is now six months since the changes in the harmonised structure for management systems required those seeking certification to consider if climate change was relevant to the system and its objectives. The key text changes to the structure are within section 4, Context, as follows:
- 4.1, the following was added –
- The organisation shall determine whether climate change is a relevant issue
- A note was also added to the structure under 4.2, Interested Parties:
- NOTE: Relevant interested parties can have requirements related to climate change
As the new text is a requirement (a ‘shall’) this means that organisations must demonstrate that they have delivered this activity. Simply, climate change must be considered in case it may have potential impact upon the effectiveness of the management system.
Some examples of where climate change might be relevant for different standards include:
- Quality Management: Changes to supplier chains should climate change disrupt or interfere with existing sources of goods or service. Might it no longer be possible to receive specific food stuffs grown in certain parts of the world or may extreme weather patterns stop delivery. This may then impact the organisation’s ability to meet customer requirements.
- Cooling systems that support secure servers may have to be re-engineered should they be critical to information security in an ISO 27001 ISMS.
- Will climate require organisations to reconsider hazards relevant to their workforce who may operate outside. This would have to be reflected in an OHSMS certified to ISO 45001
As it is now a requirement, certification bodies may now raise nonconformance if they believe that there has not been any determination on the impacts of climate change. However, evidence suggests that they continue to be taking a gentle approach to this update and there are very few, if any, examples of nonconformance known to us at present.
In the UK, UKAS has been working with Certification bodies – ensuring that the change is interpreted and applied consistently. Certification bodies have been training their auditors to ask the question – but agree that most auditors are unlikely to become climate change experts. Like anything else within the clause 4.1 – the auditor wants to be satisfied that it has at least been reviewed and that climate change colours the controls within the management system where relevant. Failure to consider the change or if an auditor clearly sees the impact of climate change not being considered may lead to nonconformance!
If you have certification, you may be concerned about the amendments, their implications and what you might have to do to remain in conformance (for any management system standard) then do get in touch with QCS, we can assist in interpretation and application of the updated requirements around climate change.