Alignment with ISO 14001:2004

1. Alignment withISO 14001:2004 Cholamandalam MS Risk Services Limited

2. Do you know? ISO 14001:1996 has now been revised to ISO 14001:2004 The new clause-wise requirements to align your existing system with this new version are explained in subsequent slides

3. New requirements – Clause 3.0 3. Definitions 7 new terms are included, primarily for harmonisation and compatibility with ISO 9001:2000 • audit • Document • Procedure • Record • nonconformity • corrective action and • preventive action • Need to check for consistency if EMS contains definitions.

4. New requirements – Clause 4.1 4.1 General requirements More explicit on: • The need to clearly define the scope of the EMS. • Scope should link the EMS to activities, services and products • The need to evaluate and document how its EMS fulfils the requirements of ISO 14001 • The need to demonstrate continual improvement of the EMS.

5. New requirements – Clause 4.2 4.2 Environmental policy • Policy shall include commitment to comply with legal and other requirements which relate to its environmental aspects (Existing version mentions only environmental legislation). • It can include Health & Safety regulations for instance, if applicable to environmental aspects. • More explicit regarding communication of policy to persons working on its behalf (not only to employees as in ’96-edition)

6. New requirements - Clause 4.3.1 4.3.1 Environmental aspects More explicit on: • Inclusion of planned or new developments and new or modified activities, products and services within the aspects identification process • Products (or services) need to be included. • Clear requirement for the information from the aspect identification process to be documented

7. New requirements - Clause 4.3.2 4.3.2 Legal and other requirements More explicit on: • ‘Legislative’ replaced by ‘legal’ which is broad to include others like court decisions. • The organization shall determine how they apply to its environmental aspects, not just the significant ones. • Non-environmental legal and other requirements may have to be included (certain safety regulations linked to environmental aspects). • Ensuring that environmental legal and other environmental requirements to which the organization subscribes are considered in developing, implementing and maintaining the EMS.

8. New requirements - Clause 4.3.3 4.3.3 Objectives, targets and programme (s) • No major changes • Minor changes are: • More explicit to address that objectives and targets shall be consistent with commitment to continual improvement (also for environmental performance). • Text under former Clause 4.3.4 on programmes has been merged into this clause.

9. New requirements - Clause 4.4.1 4.4.1 Resources, roles, responsibility and authority • No major changes • Minor changes are: • The word ‘provide’ replaced with ‘ensure availability’ (mostly related to competent auditors) • Potentially more responsibilities to the management representative when reporting to the top management (see 4.6), including recommendations for improvement. • Resources mean organizational infrastructure (facilities and equipment) • Key EMS roles, responsibilities and authority should be communicated to all persons working forand behalf of the organization

10. New requirements - Clause 4.4.2 4.4.2 Competence, training and awareness • The new version is more explicit requiring procedure for awareness “training” also for relevant persons working on behalf of the organisation, which could include contractors, temporary staff, remote workers • Communication of environmental policy (ref. 4.2) to “external” persons can be in alternative forms to the policy statement itself, such as rules, directives and procedures covering pertinent sections of the policy • Competence evaluation to cover all persons working for and on behalf of the organisation

11. New requirements - Clause 4.4.3 4.4.3 Communication • The organization shall decide whether to communicate externally about its significant environmental aspects and document its decision. If the decision is to communicate, a method shall be established. (it is expected that most of the organizations will prefer to communicate externally than to issue a documented decision not to communicate) • The emphasis is on proactive communication and not just responses to public complaints or mandatory communication to regulatory authorities

12. New requirements - Clause 4.4.4 4.4.4 Documentation • More aligned to ISO 9001:2000 • Requirement is simplified. Explicitly mentions ‘Operational control’ where their absence could lead to deviation’

13. New requirements - Clause 4.4.5 4.4.5 Control of documents Changes are: • Closer alignment to ISO 9001:2000 in terms of content and clausal structure. • More explicit requirement to control documents of external origin. • The term document is now clearly defined and is same as for ISO 9001:2000

14. New requirements - Clause 4.4.6 4.4.6 Operational Control • No major change • Explicit on need for documented procedures where their absence could lead to deviations from Environmental Policy and objectives and targets

15. New requirements - Clause 4.4.7 4.4.7 Emergency Preparedness and response • No major change • Requirement to periodically review procedures and clear requirement to respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmentalimpacts.

16. New requirements - Clause 4.5.1 4.5.1 Monitoring and measurement The new version no longer requires a “documented procedure”, but requires procedure (s) that include (s) the documenting of information required to monitor performance, applicable operational controls and conformity with objectives and targets.

17. New requirements - Clause 4.5.2 4.5.2 Evaluation of compliance • New clause partly covered by 4.5.1 in 1996-edition. Split into 2 sub-clauses. Requires evaluation of compliance for both • legal environmental requirements (4.5.2.1) and • other requirements (4.5.2.2) • The changes made imply that this issue have been given more emphasis.

18. New requirements - Clause 4.5.3 4.5.3 Nonconformity, corrective action and preventive action This clause have been reworded for clarity. New version more clearly requires: • Investigation and determination of causes related to actual non-conformities to avoid their recurrence. • Procedure for evaluating need for action (s) to prevent occurrence of potential nonconformities • Records of the results of taken corrective and/or preventive actions, and • Review of the effectiveness of the actions taken.

19. New requirements - Clause 4.5.4 4.5.4 Control of records Alignment with ISO 9001:2000 requires storage, protection, retrieval and retention of records

20. New requirements - Clause 4.5.5 4.5.5 Internal Audit This clause has been reworded for clarity. It is expected that the common auditing standard ISO 19011:2002 be used for guidance. Objectivity, Impartiality and Independence of auditors is emphasized

21. New requirements - Clause 4.6 4.6 Management review The new version has been harmonised with ISO 9001:2000, with a more detailed list of agenda/content for Management Review. Few of the inputs to management review shall include: • results of internal audits and evaluations of compliance with legal requirements and with other requirements; • Communication (s) from external interested parties, including complaints; • the environmental performance of the organization; • status of corrective and preventive actions; • follow-up actions from previous management reviews