The ISO Climate Change Amendments and Their Impact on Certified Companies and Auditors

SimpleQuE infographic of the ISO 9001 Climate Change Amendments and how they could impact your business

What certified companies and auditors should know about the new ISO Climate Change Amendments 

The new Climate Change Amendments have been added to ISO 9001 and over 30 other Management System Standards by The International Organization for Standardization (ISO) to ensure that climate change issues are considered by organizations in the context of the effectiveness of the management system.  In a previous article, about the Climate Action Amendments, we looked at what has changed and the implications for companies certified to the amended standards.

This article examines what needs to be considered when auditing or being audited to the Climate Change Amendments. We looked at guidance from ISO and IAF, as well as, the ANSI National Accreditation Board (ANAB) and various certification bodies. Clauses 4.1 and 4.2 of ISO 9001 (which flows into other harmonized structures like ISO 14001, ISO 45001, etc.) state the need for organizations to consider all internal and external issues that can impact the effectiveness of their management system. The new amendments ensure that climate change is now considered within the management system. With April being designated as Earth Month, it is appropriate to celebrate our planet and take action to protect it and prepare homes and businesses to effectively manage and mitigate the effects of climate change. The success and sustainability of your business may depend upon it.

Understanding the ISO Climate Change Amendments

Clause 4.1 added:  The organization shall determine whether climate change is a relevant issue.

Clause 4.2 added:  Note: Relevant interested parties can have requirements related to climate change.

These additions are more of a clarification rather than a new requirement. What this translates to for certified organizations is that they have to consider climate change aspects and risks within the development, maintenance, and effectiveness of their own management system(s). Climate change, along with other issues, should be determined as relevant or not and if so, considered within an evaluation of risk, within the scope of the management systems standards. Where an organization operates more than one management system (for example Quality Management and Health and Safety Management), it should ensure that climate change, if determined to be relevant, is considered within the scope of each management system standard.

What is required of a certified company?

Certified organizations (including applicants) need to consider if Climate Change is a relevant issue within their own management system(s).

If yes, the organization must consider it within their system’s objectives and risk evaluation, within the scope of their management system(s).

If no, provide evidence that climate change is not within their quality management system scope (as considered by management), or is not an issue.  Evidence may be documented in management review minutes with discussion of the topic and decision recorded, or shown in the quality manual. 

What will Certification Body auditors be looking for as evidence of conformance?

Certification Bodies (CB) have indicated their auditors will begin discussing climate awareness and considerations during audits, as there is no transition period and the amendments are now effective. This means awareness of the climate change amendment and consideration of its impact are key. Evidence of conformance can be achieved through the interview process and/or records such as a risk analysis, internal audit, and/or the management review. While a clear lack of consideration demonstrated through the interview process and records review may result in a minor nonconformance against sections 4.1 or 4.2 of the management standards, most likely, in the initial phase of this rollout, it may be noted as an Opportunity For Improvement (OFI).

On the flip side, if an organization determines climate change is irrelevant to their management system, CBs will evaluate the effectiveness of the organization’s process in making this decision.

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Auditing climate change issues

The Auditing Practices Group (APG) prepared a document on Auditing Climate Change issues in ISO 9001 to support and guide 1st, 2nd and 3rd party auditors. Consistent with ISO 19011:2018 Guidelines for auditing management systems, auditors must maintain objectivity and neutrality when auditing climate change issues. The role of the auditor is to assess whether the organization determined if climate change is relevant or not in relation to their system and its intended results, and if so, how it is addressed in the management system.

Are there relevant issues that will affect the organization’s ability to achieve the intended results of the management system and provide products and services that meet customer and applicable statutory and regulatory requirements?

Some examples of evidence of consideration and compliance:

Energy supplier invoices stating the percentage of supplied energy coming from renewable sources, claims on carbon credit, claims on products of energy consumption reduction, replacement of raw materials or consideration of eco-design of products to reduce climate change impacts.

4.1  Climate Requirement: The organization shall determine whether climate change is a relevant issue.

APG offers auditing suggestions for climate change impacts from external and internal issues. A sampling is presented here as questions for companies and auditors to consider:

  • Have changes occurred in statutory or regulatory requirements such as restrictions on the use of certain materials, product origin, claims, etc.?
  • Is the organization making use of bio-based, renewable materials?
  • Are there potential impacts on the products and services or on the QMS processes, by changes determined in other linked management systems, e.g. need to reduce energy consumption, reduce waste, reuse or recycle materials?
  • Are customers or stakeholders requiring adoption of carbon neutral products and services?
  • Possible issues impacting the processes and infrastructure, due to energy and other considerations?
  • Is the organization and delivery of its products and services vulnerable to factors like storms, floods, fires, drought, that may cause supply shortages or delays in distribution?
  • Are there concerns regarding overall knowledge and control of the supply chain in climate change related issues?

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

Has the organization determined the existence of applicable requirements related to climate change from relevant interested parties?

Examples of audit questions of relevant interested party requirements for climate change to consider:

  • Do statutory and regulatory, environmental or climate change requirements exist for the product or service provided, and could they affect the organization’s ability to provide that product or service?
  • Are there customer requirements regarding climate considerations, zero discharge, or carbon neutrality of the products?
  • Does the parent company have climate change policies and strategies?
  • Are there requirements related to product information on aspects related to climate change (sustainability of the origin, reuse, recyclability, end of life, embedded carbon, etc.), including product claims and associated existing legal, statutory, and other requirements?
  • Does the organization have environmental agreements with community groups or non-governmental organizations?
  • Do permits, licenses, or other forms of environmental authorization exist?
  • Are there climate change related requirements on processes such as packaging, manufacturing, servicing, logistics, etc.?

In summary, these examples and questions are a good starting point when auditing on the consideration and compliance of climate change within the context of the quality management system. APG provides further guidance for addressing the issues when they are considered to be relevant or when there are other stakeholders’ requirements related to climate change.

Resources for organizations and auditors – free download of Amendments (search for Climate Action Amendment)

ANAB Heads Up #527

For more information, including list of standards impacted, read the Joint ISO/IAF Communique, and your Certification Body can provide further guidance.

ISO 9001 Auditing Practices Group – Guidance On Auditing Climate Change issues in ISO 9001


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