TÜV America Management Service Division American Society for

TÜV America Management Service Division American Society for Quality’s 2005 National Energy and Environmental Conference TÜV SÜD Page 1

Management Service Division ISO 14001: 2004 Overview TÜV SÜD Page 2

Presented by: James W. Melloni, Jr. TÜV SÜD Page 3

TÜV America Presented By: Jim Melloni Lead Auditor TÜV America 5 Cherry Hill Drive Danvers, Massachusetts 01923 Phone: (978) 739 -7062 Fax: (978) 762 -8414 E-Mail: jmelloni@tuvam. com TÜV SÜD Page 4

Why was ISO 14001 revised? • It was due for revision, ISO requires that all management system standards undergo periodic revision • To enhance compatibility with ISO 9001: 2000 • Revision allows opportunity to clarify requirements in the 1996 version and incorporate needed changes TÜV SÜD Page 5

ISO 14001: 1996 4. 1 General Requirements The organization shall establish and maintain an environmental management system, the requirements of which are described in the whole of clause 4. TÜV SÜD Page 6

ISO 14001: 2004 4. 1 General Requirements The organization shall establish, document, implement, maintain and continually improve an environmental management system in accordance with the requirements of this International Standard and determine how it will fulfill these requirements. The organization shall define and document the scope of its environmental management system. TÜV SÜD Page 7

4. 2 Environmental Policy ISO 14001: 1996 ISO 14001: 2004 Top management shall define the organization's environmental policy and ensure that it: ensure that, within the defined scope of its environmental management system, it: a) is appropriate to the nature, scale and environmental impacts of its activities, products or services; a) is appropriate to the nature, scale and environmental impacts of its activities, products and services, b) includes a commitment to continual improvement and prevention of pollution; b) includes a commitment to continual improvement and prevention of pollution, TÜV SÜD Page 8

4. 2 Environmental Policy ISO 14001: 1996 ISO 14001: 2004 c) includes a commitment to comply with relevant environmental legislation applicable legal requirements and regulations, and with other requirements to which the organization subscribes which relate organization subscribes; to its environmental aspects, d) provides the framework for setting and reviewing environmental objectives and targets; d) provides the framework for setting and reviewing environmental objectives and targets, TÜV SÜD Page 9

4. 2 Environmental Policy ISO 14001: 1996 ISO 14001: 2004 e) is documented, implemented and maintained and communicated to all employees; f) is available to the public. f) is communicated to all persons working for or on behalf of the organization, and g) is available to the public. TÜV SÜD Page 10

4. 3. 1 Environmental Aspects ISO 14001: 1996 ISO 14001: 2004 The organization shall establish and maintain (a) procedure(s) The organization shall establish, implement and maintain a procedure(s) to identify the environmental aspects of its a) to identify the environmental aspects activities, products or services of its activities, products and services within the defined scope of the environmental management system that it can control and over which it can that it can control and those that it can be expected to have an influence, influence taking into account planned or new developments, or new or modified activities, products and services, and TÜV SÜD Page 11

4. 3. 1 Environmental Aspects ISO 14001: 1996 ISO 14001: 2004 in order to determine those which have or can have significant impacts on the environment. b) to determine those aspects that have or can have significant impact(s) on the environment (i. e. significant environmental aspects). The organization shall ensure that the aspects related to these significant impacts are considered in setting its environmental objectives. The organization shall document this information and keep it up to date. The organization shall keep this information up-to-date. The organization shall ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system. TÜV SÜD Page 12

4. 3. 2 Legal and Other Requirements ISO 14001: 1996 ISO 14001: 2004 The organization shall establish and maintain a procedure The organization shall establish, implement and maintain a procedure(s) to identify and have access to legal and other requirements to which the organization subscribes, a) to identify and have access to the applicable legal requirements and other requirements to which the organization subscribes related to its environmental aspects, and Connects the applicable legal requirements and other requirements to the organization’s environmental aspects TÜV SÜD Page 13

4. 3. 2 Legal and Other Requirements ISO 14001: 1996 ISO 14001: 2004 that are applicable to the environmental aspects of its activities, products or services. b) to determine how these requirements apply to its environmental aspects. The organization shall ensure that these applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing and maintaining its environmental management system. Requires detail of the applicable regulation, 40 CFRxxx. y TÜV SÜD Page 14

4. 3. 3 Objectives, Targets and Programme(s) ISO 14001: 2004 Combines 4. 3. 3 and 4. 3. 4 ISO 14001: 1996 ISO 14001: 2004 4. 3. 3 Objectives and targets 4. 3. 3 Objectives, targets and programme(s) The organization shall establish and The organization shall establish, maintain documented environmental implement and maintain documented objectives and targets, at each relevant environmental objectives and function and level within the organization. targets, at relevant functions and levels within the organization. The objectives and targets shall be measurable, where practicable, and consistent with the environmental policy, including the commitments to prevention of pollution, to compliance with applicable legal requirements and with other requirements to which the organization subscribes, and to continual improvement. TÜV SÜD Page 15

4. 3. 3 Objectives, Targets and Programme(s) ISO 14001: 1996 ISO 14001: 2004 4. 3. 3 Objectives and targets 4. 3. 3 Objectives, targets and programme(s) When establishing and reviewing its objectives, When establishing and reviewing its objectives and targets, an organization shall consider the legal and other requirements, an organization shall take into account the legal requirements and other requirements to which the organization subscribes, and its significant environmental aspects, its significant environmental aspects. It technological options and its financial, shall also consider its technological operational and business requirements, options, its financial, operational and the views of interested parties. The business requirements, and the objectives and targets shall be consistent views of interested parties. with the environmental policy, including the commitment to prevention of pollution. TÜV SÜD Page 16

4. 3. 3 Objectives, Targets and Programme(s) ISO 14001: 1996 ISO 14001: 2004 4. 3. 4 Environmental management program(s) 4. 3. 3 Objectives, targets and programme(s) The organization shall establish and maintain (a) program(s) for achieving its objectives and targets. It shall include a) designation of responsibility for achieving objectives and targets at each relevant function and level of the organization; The organization shall establish, implement and maintain a programme(s) for achieving its objectives and targets. Programme(s) shall include a) designation of responsibility for achieving objectives and targets at relevant functions and levels of the organization, and b) the means and time-frame by which they are to be achieved. If a project relates to new developments and new or modified activities, products or services, program(s) shall be amended where relevant to ensure that environmental management applies to such projects. TÜV SÜD Page 17

4. 4. 1 ISO 14001: 2004 new title ISO 14001: 1996 ISO 14001: 2004 4. 4. 1 Structure and responsibility 4. 4. 1 Resources, roles, responsibility and authority Roles, responsibility and authorities shall Management shall ensure the availability of resources essential to establish, be defined, documented and implement, maintain and improve communicated in order to facilitate the environmental management effective environmental management. system. Resources include human resources and specialized skills, Management shall provide resources organizational infrastructure, essential to the implementation and technology and financial resources. control of the environmental management system. Resources include human Roles, responsibilities and authorities resources and specialized skills, shall be defined, documented and technology and financial resources. communicated in order to facilitate effective environmental management. TÜV SÜD Page 18

4. 4. 1 ISO 14001: 1996 ISO 14001: 2004 4. 4. 1 Structure and responsibility 4. 4. 1 Resources, roles, responsibility and authority The organization’s top management shall appoint (a) specific management representative(s) who, irrespective of other responsibilities, shall have defined roles, responsibilities and authority for The organization's top management shall appoint a specific management representative(s) who, irrespective of other responsibilities, shall have defined roles, responsibilities and authority for a) ensuring that environmental management system requirements are established, implemented and maintained in accordance with this International Standard; a) ensuring that an environmental management system is established, implemented and maintained in accordance with the requirements of this International Standard, TÜV SÜD Page 19

4. 4. 1 ISO 14001: 1996 ISO 14001: 2004 4. 4. 1 Structure and responsibility 4. 4. 1 Resources, roles, responsibility and authority b) Reporting on the performance of the b) reporting to top management on the performance of the environmental management system to management system for review, top management for review and as a including recommendations for basis for improvement of the improvement. environmental management system. TÜV SÜD Page 20

4. 4. 2 Competence, training and awareness ISO 14001: 1996 ISO 14001: 2004 4. 4. 2 Training, awareness and competence 4. 4. 2 Competence, training and awareness The organization shall identify training needs. It shall require that all personnel whose work may create a significant impact upon the environment, have received appropriate training. The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records. TÜV SÜD Page 21

4. 4. 2 Competence, training and awareness ISO 14001: 1996 ISO 14001: 2004 4. 4. 2 Training, awareness and competence 4. 4. 2 Competence, training and awareness It shall establish and maintain procedures to The organization shall establish, implement make its employees or members at and maintain a procedure(s) to make each relevant function an level aware of persons working for it or on its behalf aware of a) the importance of conformance with the a) the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system; environmental management system, TÜV SÜD Page 22

4. 4. 2 Competence, training and awareness ISO 14001: 1996 ISO 14001: 2004 4. 4. 2 Training, awareness and competence 4. 4. 2 Competence, training and awareness b) The significant environmental impacts, b) the significant environmental aspects actual or potential, of their work and related actual or potential impacts activities and the environmental associated with their work, and the benefits of improved personal environmental benefits of improved performance; personal performance, c) Their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the environmental management system, including emergency preparedness and response requirements; c) their roles and responsibilities in achieving conformity with the requirements of the environmental management system, and TÜV SÜD Page 23

4. 4. 2 Competence, training and awareness ISO 14001: 1996 ISO 14001: 2004 4. 4. 2 Training, awareness and competence 4. 4. 2 Competence, training and awareness d)The potential consequences of departure d) the potential consequences of from specified operating procedures. departure from specified procedures. Personnel performing the tasks which can cause significant environmental impacts shall be competent on the basis of appropriate education, training and/ or experience TÜV SÜD Page 24

ISO 14001: 1996 4. 4. 3 Communication With regard to its environmental aspects and environmental management system, the organization shall establish and maintain procedures for a) internal communication between the various levels and functions of the organization; b) receiving, documenting and responding to relevant communication from external interested parties. TÜV SÜD Page 25

ISO 14001: 1996 4. 4. 3 Communication The organization shall consider processes for external communication on its significant environmental aspects and record its decision. TÜV SÜD Page 26

ISO 14001: 2004 4. 4. 3 Communication With regard to its environmental aspects and environmental management system, the organization shall establish, implement and maintain a procedure(s) for a) internal communication among the various levels and functions of the organization, b) receiving, documenting and responding to relevant communication from external interested parties. TÜV SÜD Page 27

ISO 14001: 2004 4. 4. 3 Communication The organization shall decide whether to communicate externally about its significant environmental aspects, and shall document its decision. If the decision is to communicate, the organization shall establish and implement a method(s) for this external communication. TÜV SÜD Page 28

ISO 14001: 1996 4. 4. 4 Environmental management system documentation The organization shall establish an maintain information, in paper or electronic form, to a) describe the core elements of the management system and their interaction; b) provide direction to related documentation TÜV SÜD Page 29

ISO 14001: 2004 4. 4. 4 Documentation The environmental management system documentation shall include a) the environmental policy, objectives and targets, b) description of the scope of the environmental management system, c) description of the main elements of the environmental management system and their interaction, and reference to related documents, d) documents, including records, required by this International Standard, and e) documents, including records, determined by the organization to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects. TÜV SÜD Page 30

4. 4. 5 Control of documents ISO 14001: 1996 ISO 14001: 2004 4. 4. 5 Document control 4. 4. 5 Control of documents The organization shall establish and Documents required by the environmental maintain procedures for controlling all management system and by this documents required by this International Standard shall be Standard to ensure that controlled. Records are a special type of document and shall be controlled in accordance with the requirements given in 4. 5. 4. The organization shall establish, implement and maintain a procedure(s) to: a) they can be located; a) approve documents for adequacy prior to issue, TÜV SÜD Page 31

4. 4. 5 Control of documents ISO 14001: 1996 ISO 14001: 2004 4. 4. 5 Document control 4. 4. 5 Control of documents b) they are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel; b) review and update as necessary and re-approve documents, c) the current versions of relevant c) documents are available at all locations where operations essential to the effective functioning of the environmental management system are performed; ensure that changes and the current revision status of documents are identified, TÜV SÜD Page 32

4. 4. 5 Control of documents ISO 14001: 1996 ISO 14001: 2004 4. 4. 5 Document control 4. 4. 5 Control of documents d) obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use; d) ensure that relevant versions of applicable documents are available at points of use, e) any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified. e) ensure that documents remain legible and readily identifiable, ISO 14001: 2004(E) TÜV SÜD Page 33

4. 4. 5 Control of documents ISO 14001: 1996 ISO 14001: 2004 4. 4. 5 Document control 4. 4. 5 Control of documents Documentation shall be legible, dated (with f) dates of revision) and readily identifiable, maintained in an orderly manner and retained for a specified period. Procedures and responsibilities shall be established and maintained concerning the creation and modification of the various types of documents. g) ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the environmental management system are identified and their distribution controlled, and prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose. TÜV SÜD Page 34

4. 4. 6 Operational control ISO 14001: 1996 ISO 14001: 2004 The organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. The organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by: The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, by: TÜV SÜD Page 35

4. 4. 6 Operational control ISO 14001: 1996 ISO 14001: 2004 a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets; a) establishing, implementing and maintaining a documented procedure(s) to control situations where their absence could lead to deviation from the environmental policy, objectives and targets, and b) stipulating operating criteria in the procedures; b) stipulating the operating criteria in the procedure(s), and TÜV SÜD Page 36

4. 4. 6 Operational control ISO 14001: 1996 ISO 14001: 2004 c) establishing and maintaining c) establishing, implementing and procedures related to the identifiable maintaining procedures related to the significant environmental aspects of identified significant environmental goods and services used by the aspects of goods and services used by organization and communicating the organization and communicating relevant procedures and requirements applicable procedures and to suppliers and contractors. requirements to suppliers, including contractors. TÜV SÜD Page 37

4. 4. 7 Emergency preparedness and response ISO 14001: 1996 ISO 14001: 2004 The organization shall establish and maintain procedures to identify potential for and respond to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them. The organization shall establish, implement and maintain a procedure(s) to identify potential emergency situations and potential accidents that can have an impact(s) on the environment and how it will respond to them. The organization shall respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmental impacts. TÜV SÜD Page 38

4. 4. 7 Emergency preparedness and response ISO 14001: 1996 ISO 14001: 2004 The organization shall review and revise, The organization shall periodically review where necessary, its emergency and, where necessary, revise its preparedness and response emergency preparedness and procedures, in particular, after the response procedures, in particular, occurrence of accidents or emergency after the occurrence of accidents or situations. emergency situations. The organization shall also periodically test such procedures where practicable. TÜV SÜD Page 39

4. 5. 1 Monitoring and measurement ISO 14001: 1996 ISO 14001: 2004 The organization shall establish and The organization shall establish, maintain documented procedures to implement and maintain a procedure(s) monitor and measure, on a regular to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a operations that can have a significant impact on the environmental impact. This shall include the recording of information to track performance, relevant operational controls and conformance with the organization’s environmental objectives and targets. The procedure(s) shall include the documenting of information to monitor performance, applicable operational controls and conformity with the organization's environmental objectives and targets. TÜV SÜD Page 40

4. 5. 1 Monitoring and measurement ISO 14001: 1996 ISO 14001: 2004 Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organization's procedures. The organization shall ensure that calibrated or verified monitoring and measurement equipment is used and maintained and shall retain associated records. The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations ISO 14001: 2004 removes “compliance with relevant environmental legislation and regulations” and provides new sub-clause 4. 5. 2 TÜV SÜD Page 41

4. 5. 2 Evaluation of compliance ISO 14001: 1996 ISO 14001: 2004 4. 5. 1 Monitoring and measurement (3 rd paragraph) 4. 5. 2. 1 The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations Consistent with its commitment to compliance, the organization shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements. The organization shall keep records of the results of the periodic evaluations. TÜV SÜD Page 42

4. 5. 2 Evaluation of compliance ISO 14001: 2004 4. 5. 2. 2 The organization shall evaluate compliance with other requirements to which it subscribes. The organization may wish to combine this evaluation with the evaluation of legal compliance referred to in 4. 5. 2. 1 or to establish a separate procedure(s). The organization shall keep records of the results of the periodic evaluations. TÜV SÜD Page 43

ISO 14001: 1996 4. 5. 2 Nonconformance and corrective and preventive action The organization shall establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused, and for initiating and completing corrective and preventive action. Any corrective or preventive action taken to eliminate the causes of actual and potential nonconformances shall be appropriate to the magnitude of problems and commensurate with the environmental impact encountered. The organization shall implement and record any changes in the documented procedures resulting from corrective and preventive action TÜV SÜD Page 44

ISO 14001: 2004 4. 5. 3 Nonconformity, corrective action and preventive action The organization shall establish, implement and maintain a procedure(s) for dealing with actual and potential nonconformity(ies) and for taking corrective action and preventive action. The procedure(s) shall define requirements for: a) identifying and correcting nonconformity(ies) and taking action(s) to mitigate their environmental impacts, b) investigating nonconformity(ies), determining their cause(s) and taking actions in order to avoid their recurrence, c) evaluating the need for action(s) to prevent nonconformity(ies) and implementing appropriate actions designed to avoid their occurrence, TÜV SÜD Page 45

ISO 14001: 2004 4. 5. 3 Nonconformity, corrective action and preventive action d) recording the results of corrective action(s) and preventive action(s) taken, and e) reviewing the effectiveness of corrective action(s) and preventive action(s) taken. Actions taken shall be appropriate to the magnitude of the problems and the environmental impacts encountered. The organization shall ensure that any necessary changes are made to environmental management system documentation. TÜV SÜD Page 46

ISO 14001: 1996 ISO 14001: 2004 4. 5. 3 Records 4. 5. 4 Control of records The organization shall establish and maintain procedures for the identification, maintenance and disposition of environmental records. These records shall include training records and the results of audits and reviews. The organization shall establish and maintain records as necessary to demonstrate conformity to the requirements of its environmental management system and of this International Standard, and the results achieved. TÜV SÜD Page 47

ISO 14001: 1996 ISO 14001: 2004 4. 5. 3 Records 4. 5. 4 Control of records Environmental records shall be legible, The organization shall establish, implement identifiable and traceable to the and maintain a procedure(s) for the activity, product or service involved. identification, storage, protection, Environmental records shall be stored retrieval, retention and disposal of and maintained in such a way that they records. are readily retrievable and protected against damage, deterioration or loss. Their retention times shall be established and recorded. Records shall be maintained, as appropriate to the system and to the organization, to demonstrate conformance to the requirements of this International Standard. Records shall be and remain legible, identifiable and traceable. TÜV SÜD Page 48

ISO 14001: 1996 4. 5. 4 Environmental management system audit ISO 14001: 2004 4. 5. 5 Internal audit The organization shall establish and maintain The organization shall ensure that internal audits of the environmental management (a) program(s) and procedures for system are conducted at planned periodic environmental management intervals to: system audits to be carried out, in order to a) determine whether or not the environmental management system: conforms to planned arrangements for environmental management including the requirements of this International Standard; and 2) has been properly implemented and maintained; and 1) b) provide information on the results of audits to management. a) determine whether the environmental management system conforms to planned arrangements for environmental management including the requirements of this International Standard, and 2) has been properly implemented and is maintained, and 1) b) provide information on the results of audits to management. TÜV SÜD Page 49

ISO 14001: 1996 4. 5. 4 Environmental management system audit ISO 14001: 2004 4. 5. 5 Internal audit Audit programme(s) shall be planned, established, The organization’s audit program, including any implemented and maintained by the schedule, shall be based on the environmental organization, taking into consideration the importance of the activity concerned and the environmental importance of the operation(s) results of previous audits. In order to be concerned and the results of previous audits. comprehensive, the audit procedures shall cover the audit scope, frequency and Audit procedure(s) shall be established, methodologies, as well as the responsibilities implemented and maintained that address the and requirements for conducting audits and responsibilities and requirements for planning reporting results. and conducting audits, reporting results and retaining associated records, — the determination of audit criteria, scope, frequency and methods. Selection of auditors and conduct of audits shall ensure objectivity and the impartiality of the audit process. TÜV SÜD Page 50

4. 6 Management Review ISO 14001: 1996 ISO 14001: 2004 The organization’s top management shall, at Top management shall review the organization's environmental management intervals it determines, review the system, at planned intervals, to ensure its environmental management system, to continuing suitability, adequacy and ensure its continuing suitability, adequacy effectiveness. Reviews shall include and effectiveness. The management assessing opportunities for improvement review process shall ensure that the and the need for changes to the necessary information is collected to allow environmental management system, management to carry out this evaluation. including the environmental policy and This review shall be documented. environmental objectives and targets. Records of the management reviews shall be retained. TÜV SÜD Page 51

4. 6 Management Review ISO 14001: 1996 ISO 14001: 2004 The management review shall address the possible need for changes to policy, objectives and other elements of the environmental management system, in the light of environmental management system audit results, changing circumstances and the commitment to continual improvement Input to management reviews shall include a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes, b) communication(s) from external interested parties, including complaints, c) the environmental performance of the organization, TÜV SÜD Page 52

4. 6 Management Review ISO 14001: 2004 continued d) e) f) g) the extent to which objectives and targets have been met, status of corrective and preventive actions, follow-up actions from previous management reviews, changing circumstances, including developments in legal and other requirements related to its environmental aspects, and h) 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. TÜV SÜD Page 53

FAQ Do I need to rename or renumber my existing documents? No, your existing document names and numbers can be maintained with only minor revisions needed to meet the revised requirements TÜV SÜD Page 54

FAQ When do I need to make these changes? • May 15, 2006 • After this date any certification to ISO 14001: 1996 will no longer be recognized • Until the nonconformances are addressed the certification to ISO 14001: 1996 remains valid until May 15, 2006 TÜV SÜD Page 55

FAQ When do I need to make these changes? • Registrars are required by the International Accreditation Forum (IAF) to conduct all audits after May 15, 2005 using ISO 14001: 2004 – Areas of the management system that do not conform to the new/modified 2001 requirements will be documented on a nonconformity report – When corrected a revised certificate will be issued – Usually an additional visit is not necessary TÜV SÜD Page 56

Conclusion TÜV SÜD Page 57

Conclusion TÜV SÜD Page 58

Conclusion • ISO 14001: 2004 changes are more “evolutionary” than “revolutionary”. • Many existing certified ISO 14001: 1996 organizations may already have evidence of meeting ISO 14001: 2004 requirements. Documentation, Records, Corrective Action, Internal Auditing and Management Reviews are now closely aligned with ISO 9001: 2000. Organizations and Auditors will want to consider the context in which to apply these clauses as related to the Organization’s Environmental Aspects and Impacts. TÜV SÜD Page 59

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