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Climate change implications for auditors

Auditing climate change

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Climate change implications for auditors
Published: 5 Jun 2024

Richard Green, founder and owner of Kingsford Consultancy Services, examines the implication of ISO’s climate change amendments to management system standards for auditors.

The London Declaration of September 2021 represented a concerted effort by the International Standards Organization (ISO) and other similar parties to counter the effects of climate change and support the net zero agenda. As a result of the declaration, amendments were introduced in February 2024 that have an impact on more than 30 management system standards. These amendments require organisations to give specific thought to climate considerations during the process of determining their context.

The standards affected include those underpinning the majority of CQI and IRCA training courses including, but not limited to, ISO 9001, ISO 14001, ISO 45001, ISO/IEC 27001 and ISO 22000, with the updated editions of each standard superseding the then current edition of each standard immediately on publication.

It is therefore important that approved training partners (ATPs) and their learners are aware of the nature of the changes and their implications.

There are two elements to the 2024 amendment: the first incorporates a further requirement into clause 4.1 Understanding the organization and its context; the second introduces additional clarification, by means of a new note, into clause 4.2 Understanding the needs and expectations of interested parties.

Clause 4.1

There is now an explicit requirement that when the organisation ‘determines the external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended results of its XXX management system’ it specifically determines whether climate change is one of these relevant issues.

As this is a requirement, certificated organisations should expect their auditors to request objective evidence that this determination has been made and the organisation must be in a position to provide it.

Clause 4.2

The approach is a little different in respect of Understanding the needs and expectations of interested parties. There is still a requirement for the organisation to determine the relevant requirements of relevant interested parties, and which of these relevant requirements will be addressed through the XXX management system. There is now, however, a note to remind both the organisation and those engaged in the audit process that some of the relevant interested parties ‘can have requirements relating to climate change’.

"Auditors are not expected to become climate change experts or police; however, organisations should, of course, retain the expectation that their auditors will be competent."

Richard Green, founder and owner of Kingsford Consultancy Services

Implications for certificated organisations

The 2024 amendment does not change the overall intent of clauses 4.1 or 4.2. These remain focused on getting the organisation to think about the wider environment in which it operates and how this can impact its XXX management system and what the system is trying to achieve.

Organisations already employing political, economic, social, technological, legal and environmental (PESTLE) analysis or similar techniques are likely to be undertaking the necessary determination already, and there is certainly no need for the introduction of climate change initiatives unless climate change has been identified by this or other methods as a relevant issue in respect of achieving intended results.

From a practical perspective, organisations may find it difficult to carry out the required determination and conclude that there are no climate change issues impacting their XXX management system and its intended results. For those organisations where the determination has indicated that there is a need to update their XXX management system, the same process(es) as currently applied to address the requirements of clause 6.1 can be used to identify any actions necessary to address risk and opportunities arising from the new requirement, and the means by which these actions will be implemented and reviewed.

The impact of the 2024 amendment is going to be most significant for those certified organisations that have previously undertaken the determination, but who have then chosen not to act on a positive result, or who have introduced tokenistic measures to appease relevant interested parties. Previously, their auditor would need to have remembered to have brought climate considerations into discussions regarding Context.

Now, it is much more likely that such considerations will be ‘front and centre’ as the result of this new explicit requirement. The amount of work involved for these organisations to conform with this requirement will depend on many factors including, but not limited to, their size, complexity, range of products and/or services, production methods and industrial sector. For some, the workload will be significant.

During an audit

During audits, the organisation should expect auditors to remain objective and impartial in their determination as to whether the new requirement is met. Auditors are not expected to become climate change experts or police; however, organisations should, of course, retain the expectation that their auditors will be competent.

This may mean there is a need for some improvement in individual auditor knowledge or understanding, dependent on the extent and complexity of any climate-related initiatives introduced by the organisations they audit.

Similarly, individuals managing audit programmes will need to give consideration as to the structure of audit teams if the organisation has determined climate change is a relevant issue and has modified its XXX management system as a result. This, of course, includes those individuals within organisations responsible for managing their organisation’s first-party audit programme.

This is not a new requirement, simply a restatement that, collectively, the audit team must possess the necessary competence to conduct the audit.

The ISO 9001 Auditing Practices Group has produced useful guidance in auditing climate change issues in ISO 9001. This is relevant to those responsible for conducting audits and those who receive audit services. It is also useful for those certificated to ISO management systems other than ISO 9001.

Learn more about the development of ISO's climate change considerations

Dr Nigel Croft CQP FCQI, Chair of the ISO Joint Technical Coordination Group for Management System Standards from 2021 – 2023, takes a closer look at ISO’s climate change considerations now incorporated into management systems standards.

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