You are probably reading this as you are an existing HKW RM client and have been sent a link by Sophie and Sam (our ‘Office Wranglers’) along with an email saying that we will need to revisit your existing context analysis over the next few months.

(If you aren’t an existing HKW RM client, you are welcome to read this too and we hope you find it useful!)

All our clients hold certification to ISO 9001:2015 and we would have carried out an initial context analysis process at the beginning of the quality management system implementation project. We use a combination of the SWOT and PESTLE mnemonics, where each of the PESTLE words are used as prompts for the different sections of the SWOT:

We also review and update the SWOT analysis during the year, usually every 6 months though some clients do this quarterly, others annually – depending on the size of the business. At our next review, we need to consider climate change as this has now been explicitly added to over 30 ISO standards as part of ISO’s commitment to action on climate change which was approved at the London Declaration in September 2021. The intention of this declaration was to foster the active consideration of climate science and associated transitions in the development of all new and revised International Standards and publications. This change to the standards has not been without some controversy as some parties felt that the climate change agenda was being ‘shoehorned’ into standards unnecessarily. However, we feel that any consideration of an organisation’s context should already have included thinking about climate change as it is already affecting the way businesses and societies function across the globe. The two new statements are:

• 4.1 The organisation shall determine whether climate change is a relevant issue
• 4.2 NOTE: Relevant interested parties can have requirements related to climate change

Image from ISO 9001 Auditing Practices Group Guidance on: Auditing Climate Change issues in ISO 9001

Most of our clients will have already considered the environment and climate change as part of identifying and reviewing the context in which they operate, but we now need to make sure that climate change is explicitly covered. We would recommend this consideration process is documented so you are able to demonstrate that you have done the considering!

You will need to determine whether climate change is a relevant issue (or not) to your business. How much you discuss, document and take action will depend on the risk level to your business from the consequences of climate change. Once you have decided on relevance, you can document this decision in various places within your QMS:

• SWOT / PESTLE
• Interested Parties list
• Quality and / or Environmental Policy
• Business / Quality Manual
• Risk Register
• Opportunities (the flip side of risk is opportunity!)
• Objectives
• Management Review Meetings

Climate change impacts on your business can include everything from the obvious risks to your premises from flooding or fires to the more interesting consequences, such as the potential for:

• Regulations to change and prohibit certain carbon intensive materials
• Customer requirements to change and demand more renewable materials or a higher proportion of recycled materials in finished products
• Traditional quality management considerations to be impacted by environmental considerations such as reducing energy consumption in production, redesigning products to be more easily recycled etc
• Requirements to build products with a longer lifespan or to extend the lifespan of products through repairs and availability of spare parts
• Interruption to supply chains affecting production
• Increasing informed consumers about sustainability of products and services, who might be alert to ‘greenwashing’ and might also be looking to make purchasing decisions on environmental performance
• Customers asking for more environmental information about products and services, or asking for carbon footprint information or asking for carbon reduction plans
  
  

The ISO 9001 Auditing Practices Group Guidance on: Auditing Climate Change issues in ISO 9001 document provides information on how the new requirements will be audited and is worth a read.

We were supporting one of our clients through a certification body audit earlier this month and within the first hour the auditor had raised an Observation against the new requirements which came as rather a surprise! Fortunately, we were able to demonstrate that we had already considered climate change (before the new requirements came into effect) and it was already included in the SWOT / PESTLE analysis, the Risk Register, the Business Plan and Quality Manual so the Observation was lifted. However, we have made the decision to add climate change as an ‘one-off’ agenda item to the next Management Review Meeting to document how the QMS covers this requirement, then it can be discussed as part of the normal context review and update process.

We will be talking to all our clients about this new requirement over the next few months, if you need any help with this, or any other aspect of your QMS, please contact us!

Other useful links if you would like to find out more as follows:

• UKAS Technical Bulletin: Inclusion of Climate Change considerations within Management System Standards
• ISO Document: Climate action and ISO standards