Managing a changing climate

ISO’s commitment to furthering the global climate action agenda came during its 2021 General Assembly, when all 160+ ISO Member Bodies approved what has become known as the London Declaration, part of which reads as follows:

"ISO hereby commits to work with its members, stakeholders and partners to ensure that International Standards and publications accelerate the successful achievement of the Paris Agreement, the United Nations Sustainable Development Goals and the United Nations Call for Action on (Climate Change) Adaptation and Resilience."

A common misconception is that climate change considerations are limited to organisations that have chosen to implement an environmental management system, such as ISO 14001, or an energy management system, such as ISO 50001.

In fact, most organisations are likely to be affected by climate change in one way or another and may need to adapt to it to continue to meet their objectives and fulfil the strategic purpose of their management system.

Organisations may also choose – or be required by relevant interested parties – to take action to mitigate climate change as part of their operations. For example, this could be because of corporate policies and commitments, customer/supply chain requirements or regulatory obligations.

"Most organisations are likely to be affected by climate change in one way or another and may need to adapt to it to continue to meet their objectives."

Dr Nigel Croft CQP FCQI

ISO’s Joint Technical Coordination Group on Management System Standards (JTCG) has been working in close collaboration with ISO’s Climate Change Coordination Committee to reach agreement on how climate change considerations might be incorporated into the Harmonized Structure ('Annex SL' of the ISO Directives), which applies to just about all Management System Standards (MSS) within the ISO portfolio. The only notable exception is for ISO 13485:2016 Medical devices – Quality management systems requirements for regulatory purposes.

The proposed changes were approved by the JTCG membership – which includes the Chairs and Committee Managers of all ISO Technical Committees with one or more MSS in their portfolio – by a subsequent ballot among all ISO Member Bodies, endorsed by ISO’s Technical Management Board, and incorporated into the Harmonized Structure in November 2023, as follows:

Clause 4.1 Understanding the organization and its context.

The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended result(s) of its XXX management system.

Added: The organization shall determine whether climate change is a relevant issue.

Clause 4.2 Understanding the needs and expectations of interested parties. The organization shall determine:

• the interested parties that are relevant to the XXX management system.
• the relevant requirements of these interested parties.
• which of these requirements will be addressed through the XXX management system.

Added: NOTE: Relevant interested parties can have requirements related to climate change.

Impact of added text

For users of management system standards, determining the issues that are relevant to their scope and purpose is, of course, not a new requirement. Many organisations may have already thought about how climate change can affect their business and determined whether it is a relevant issue that needs to be addressed within their context. This will, in turn, have fed into their policies and objectives and been actioned/deployed as part of their risk and opportunity management processes.

For organisations that are only now beginning to understand how climate change might affect – or be affected by – their business, though, this change in the text of the Harmonized Structure will serve as a wake-up call.

In the case of a quality management system, some – in my view primarily those with the rather outdated view that "ISO 9001 is only for manufacturing companies" – have questioned whether climate change is a relevant issue at all. And it might not be! That is for each individual organisation to determine based on their specific context.

Indeed, some organisations might easily be able to justify why they do not need to consider climate change as a relevant issue, and that is OK.

But if, for example, you are a ski-resort operator and there is no snow for your visitors, an agri-food company whose crops are not of the usual quality because of drought, or a train operator whose services are disrupted by excessive heat – as actually happened when the UK hit 42C in 2022– then, from this broader perspective, organisations should begin to see that climate change is an issue that can affect their ability to ‘consistently provide conforming products and services’, as per ISO 9001:2015 Clause 1.1.

Two new standards (ISO 7101:2023 Healthcare organization management – management systems for quality in healthcare organization requirements and ISO/IEC 42001:2023 Information technology – Artificial Intelligence – Management system) were the first to adopt these changes while they were still in the final stages of drafting, prior to their publication in late 2023.

To speed up the deployment of the changes to all other MSSs, without having to wait for a potentially lengthy revision cycle, followed by a three-year transition period for certification, ISO and the IAF (International Accreditation Forum) came up with a ‘fast-track’ implementation plan, which can be summarised as follows:

• Amendments to a total of 31 MSS (including ISO 9001, ISO 14001, ISO 45001 and others) were issued free of charge by ISO Central Secretariat in Geneva on 29 February 2024. They can be downloaded from the ISO website.
• The IAF has determined that:
  • since the overall intent of the requirements remains unchanged, these amendments are being treated as clarifications, and a full (traditional) three-year transition programme is not needed;
  • certification bodies should include the new text in their auditing of the organisation and its context at the first opportunity to do so (scheduled surveillance or recertification audit). As with normal practice, where an organisation cannot demonstrate that all relevant issues (including climate change) have been considered, a ‘suitable finding’ should be raised*.
  • since there is no change in the publication date of the last revision to each standard, there will be no need for new certificates to be issued.

*In my opinion, it is highly unlikely that an auditor will raise a nonconformity, much less a major nonconformity that could affect an organisation’s certification status, during the first surveillance or recertification audit after the amendments have been published.

Further information about the rationale behind the changes, and their implications can be found on the JTCG website, and more information is available here.