1996 : The standard applies to " those environmental aspects which the organization can control and over which it can be expected to have an influence."

2004 : The standard applies to "those environmental aspects that the organization identifies as those it can control and those which it can influence."

This revision adds requirements by expanding the scope of the aspects for the EMS to include the environmental aspects of the organization's supply chain.

1996 : Environmental management system audit was defined, in part as "systematic and documented verification process of objectively obtaining and evaluating evidence."

2004: The term "Environmental management system audit" has been replaced by the term "Internal audit" which is defined, in part, as a "systematic, independent and documented process for obtaining audit evidence and evaluating it objectively." There is a note saying that in many cases, "particularly in smaller organizations, independence can be demonstrated by the freedom from responsibility for the activity being audited."

The new wording aims to improve compatibility with ISO 9001:2000 (and ISO 19011): ISO 14001:2004 uses the same adjectives as ISO 9001:2000 (i.e. systematic, independent and documented) to qualify the term "audit."

The new adjective "independent" (combined with the change to the internal EMS audit clause - see 4.5.5 below) adds a requirement that may limit the role of the most competent person in a small business or micro-enterprise to conduct the audit, resulting in a less valuable audit or the need for additional resources.

1996 : Nonconformity was not defined.

2004 : Nonconformity is now defined as "non-fulfilment of a requirement."

This addition aims to improve compatibility with ISO 9001:2000, as the definition is taken from that standard (3.6.2).

It also adds requirements. Previously nonconformity meant non-fulfilment of a requirement of the management system. It now includes non-fulfilment of performance requirements such as objectives, targets or legal permits.

1996 : The organization shall have a procedure(s) to identify those environmental aspects "that it can control and over which it can be expected to have an influence."

2004 : The organization shall have a procedure(s) to identify those environmental aspects "that it can control and those that it can influence."

This information has to be documented.

This revision adds requirements by expanding the scope of the aspects for the EMS to include the environmental aspects of the organization's supply chain.

New requirement

1996 : The organization shall have a procedure(s) to "identify and have access to legal and other requirements to which the organization subscribes, that are applicable to the environmental aspects of its activities, products or services."

2004 : The organization shall have a procedure(s) to:

A new requirement has been added. An organization must now determine how its legal requirements apply to its aspects. However registrants to ISO 14000:1996 were, in practice, using these procedures to establish due diligence.

2004 : The objectives and targets shall be measurable.

Making organizations specify measurable objectives and targets is a new requirement.

1996 : The organization shall consider processes for external communication and record its decision.

2004 : The organization shall decide whether to communicate externally and, if affirmative, it shall establish and implement (a) method(s) for this.

Requirements have been added by making organizations

2004 : The documentation is more precisely described.

Making organizations specify documents is a new requirement.

1996 : The organization shall have a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations.

2004 : The 2004 moves this requirement to a new clause, 4.5.2 Evaluation of Compliance, and adds that the organization shall evaluate compliance with "other requirements to which it subscribes." This evaluation may be combined with the evaluation of legal compliance or done through (a) separate procedure(s).

Making an organization evaluate its compliance with legal (recorded) and other requirements (recorded) is a new requirement.

1996 : The organization shall have procedures for assigning responsibility for investigating and handling nonconformance, taking action to mitigate impacts caused and taking corrective and preventive action.

2004 : The organization shall have (a) procedure(s) for "dealing with actual and potential nonconformity(ies) and for taking corrective action and preventive action." The procedure(s) must define requirements for

The 2004 also adds definitions: corrective action (3.3) and preventive action (3.17).

The revised text aims to improve compatibility with ISO 9001:2000, as the new definitions of corrective and preventive action are taken from that standard. Combined with the new definition of nonconformity (3.1.5 above), this adds a requirement and takes away some of an organization's flexibility in deciding how to deal with nonconformities.

1996 : The organization must have programs and procedures for periodic EMS audits.

2004 : The clause is renumbered "4.5.5 Internal Audit." The clause has been reworded mainly for clarification and new text added at the end which requires that auditor selection and the conduct of audits "shall ensure objectivity and the impartiality of the audit process."

The new text, combined with the revised definition of "internal audit" (3.14 above), adds a requirement that many small businesses may not be able to satisfy without additional resources.

1996 : The management review process must ensure that "the necessary information is collected" to allow management to evaluate the EMS. The standard does not prescribe any particular "inputs" or "outputs."

2004 : The "inputs" to management reviews shall include results of internal audits and evaluations of compliance, communications from external interested parties, the environmental performance of the organization, the extent to which objectives and targets have been met, the status of corrective and preventive actions, follow-up actions from previous management reviews, changing circumstances and recommendations for improvement.

The "outputs" from management reviews "shall include any decisions and actions related to possible changes to environmental policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement."

This change aims to improve compatibility with ISO 9001:2000. The text, taken almost directly from ISO 9001:2000, is more prescriptive in defining the management review process than the ISO 14001:1996 version (which permits an organization to have more flexibility in designing its management reviews consistent with its priorities). Note: ISO 14001:2004 now includes a performance review.