1. Introduction:
The Energy Management System Standard, ISO 50001:2011 was published in June 2011 and has had a rapid take up in over 90 countries with over 22,800 certifications by December 2017. In August 2018, a revised version was published: ISO 50001:2018. This article highlights the main changes in ISO 50001:2018 and considers their implications for organisations, who hold ISO 50001 certification or are considering building an Energy Management System (EnMS) with accredited certification in mind.
2. The Main Changes
The main changes in ISO 50001:2018 fall into four categories:
-
- changes to the structure of the Standard to the High Level Structure (HLS)
-
- general changes in ISO 50001:2018
-
- removal of requirements from ISO 50001:2011
-
- additions to the requirements in ISO 50001:2011
The rest of the article briefly describes each of the changes with reference to ISO 50001:2011 and comments on their merits and defects.
3. High Level Structure
Before looking at the High Level Structure, it is worth reviewing the structure of ISO 50001:2011 which has seven clauses:
4.1 General requirements
4.2 Management responsibility
4.3 Energy policy
4.4 Energy planning
4.5 Implementation and operation
4.6 Checking
4.7 Management review
Clauses 4.3 to 4.7 largely reflect the traditional ‘Plan, Do, Check, Act’ process as shown in Figure 1.
Figure 1 Energy Management System Model
A common structure of standards for management systems was drawn up in 2012 and applicable to the new ISO standards and future revisions of existing ISO standards. It was titled the High Level Structure (HLS).
HLS means:
-
- Terminology, text, definitions, titles and the common sequence of the same
-
- Greater importance given to the concept of risk
In particular, all management system standards present:
-
- A structure made up of 10 principal points. Within each point there are some paragraphs and content, inclusion of which is obligatory in all standards.
-
- Where necessary, the individual standards may add specific requirements in relation to their fields of application.
The idea behind HLS is to harmonise or ‘standardise’ the structure of standards. This follows a logic common to all standards, enabling better integration which aims to ease management systems building and auditing. See Figure 2.
|
Clause No |
Clause |
|
1. 2. 3. 4. 5. 6. 7. 8. 9. 10. |
Scope Normative references Terms and definitions Context of the organization
Leadership
Planning
Support
Operation
Performance evaluation
Improvement
|
Figure 2 Main Clauses of ISO 50001:2018
The main principles of HLS are:
Risk-based thinking: the risk analysis and opportunities go across all normative requirements. The specific requirement in ISO 50001:2011 dedicated to preventive actions disappears.
Context of the organisation: a knowledge of the internal and external context, as well as the needs and expectations of interested parties, leads up to a better application of the management system. It also makes it possible to analyse and provide for critical (internal and external) factors that can affect the organisation’s capacity to attain the desired results.
Leadership: top management must show leadership and commitment so that implementation of the management system is integrated in the organisation’s strategic management processes.
Planning: allows the organisation to realise the opportunities offered by the reference context, analyse related risks, and prevent negative impacts that could affect attainment of the goals.
-
- Documented information: organisations can choose the most appropriate means of preparing and keeping documentation related to their operations.
-
- Knowledge management: people’s knowledge and skills have greater emphasis, as they are considered a qualifying element to achieve the organisation’s objectives.
The structure of ISO 50001:2011 and the HLS in ISO 50001:2018 are compared in Figure 3.
Figure 3 Structures of ISO 50001:2011 and ISO 50001:2018
Clauses 4.1 to 4.7 of ISO 50001:2011 are now part of Clauses 4 to 10 of ISO 50001:2018. Was this change necessary? In a sense it is an irrelevant question as the change was going to occur, as part of ‘standardising’ the standards, whether it was needed or not.
In general the structure of ISO 50001:2011 was acceptable but there were some ill-fitting elements. For example, the structure of Clause 4.5 “Implementation and Operation” is:
4.5.1 General
4.5.2 Competence, training and awareness
4.5.3 Communication
4.5.4 Documentation
4.5.5 Operational control
4.5.6 Design
4.5.7 Procurement
Clause 4.5.4 on Documentation (highlighted) seems out of place, sandwiched between other key clauses. Also Sub-Clause 4.6.5 “Control of records” is separated from Clause 4.5.4 on Documentation.
Similarly, 4.4.2 “Legal requirements and other requirements” is separated from 4.6.2 “Evaluation of compliance with legal requirements and other requirements”. It could be argued that 4.6.2 and 4.6.5 were put in Clause 4.6 “Checking” because they were evolution elements, but it always felt awkward.
So the new HLS irons out some of these anomalies in and therefore welcomed. However, it does create a headache for those with an EnMS to ISO 50001:2011 because all the documentation and clause numbering will need changing. This will require some effort to transition from the existing structure to the new HLS. However, it is likely to be short term pain (and cost) for a long term gain. I just hope it does not provide an excuse for organisations to drop their certification altogether.
4. Changes in ISO 50001:2018
This section covers the changes which do not fit into removals and additions to requirements of ISO 50001:2011 which are described below in Section 6 and 7.
A glossary of terms and definitions may sound slightly boring to the uninitiated, however, they are of vital importance. Words and terms used in the Standard have specific meanings. It matters not what the reader of the Standard thinks a term means, but what the glossary actually says. Therefore the meaning of words is very important in interpreting the actual requirements of the Standard.
In ISO 50001:2011, Clause 3 has Terms and Definitions listed in alphabetical order and therefore easy to use. However, a backward step has been taken with the equivalent Clause 3 in ISO 50001:2018. For some reason the authors have decided to group the glossary into ‘helpful’ topics and list terms and definitions within them. This includes terms related to ‘energy’ and terms related to ‘performance’. This means the reader has a two stage mental process: firstly to guess what group the term is in and then look for it alphabetically in the group. Usually the first group guess is incorrect and therefore the eye roams across all terms until it is finally found. This is an example of a ‘helpful’ change which has proved to be unhelpful.
Many of the terms and definitions provide enlightenment but others are so opaque they have little actual meaning. For example, take the definitions of an Energy Management System in both versions of ISO 50001:
ISO 50001:2011: set of interrelated or interacting elements to establish an energy policy and energy objectives, and processes and procedures to achieve those objectives.
ISO 50001:2018: management system to establish an energy policy, objectives, energy targets, action plans, and processes to achieve the objectives and energy targets.
The ISO 50001:2018 definition is definitely an improvement but it focuses entirely on the process of an EnMS and does not mention its purpose. Here is my definition which I use when trying to put into terms senior management can understand:
An EnMS is a structured, defined and disciplined approach, applied to key aspects of energy management, to deliver continual improvement in effective energy use.
There is a tendency to include cross referenced terms (shown in blue text) in definitions in ISO 50001:2018 which renders some definitions difficult to understand. For example:
|
Energy Performance Improvement improvement in measurable results of energy efficiency (3.5.3), or energy consumption (3.5.3) related to energy use (3.5.4), compared to the energy baseline (3.4.7) |
5. Removal of Requirements from ISO 50001:2011
Some requirements have been removed from ISO 50001:2011 and are not required in ISO 50001:2018. I feel ambivalent about some of these removals, others, I think, are a backward step. Before selecting a few, it is worth saying that it does not really matter. When organisations build an EnMS they usually produce an EnMS Manual which describes their EnMS. This is not a specific documented requirement of either Standard, however, it helps the EnMS Team, the internal auditor, external auditors and other stakeholders to understand the EnMS strategy and the key components and their inter-relationship. When the EnMS Manual is written it will describe how two types of requirement are met:
-
- A specific requirement of ISO 50001
-
- A requirement specified by the organisation which is in addition to ISO 50001
When the internal auditor or external auditor is conducting an audit their scope covers both types of requirement. For example, if an organisation states in the Energy Policy they will buy 100% of imported grid electricity from renewable sources, this is a requirement of the organisation – not a requirement of ISO 50001. So if the organisation is audited and it is revealed that they no longer purchase electricity from renewable sources, they are not complaint. Not because they failed a requirement of ISO 50001 but because they failed their own requirement. Possible corrective actions are to start purchasing electricity from renewable sources again or, easier, change the policy. However, if the new policy has to be re-signed by the CEO, in some organisations it might be easier to switch back to green electricity!
If there is a removal of a requirement in the change from ISO 50001:2011 to ISO 50001:2018 and an organisation does not agree with the removal, they can keep it, simply by making it an EnMS requirement. For example, in ISO 50001:2011 there is a specific requirement for a Management Representative. (There can be more than one). It is also inferred that there is an EnMS team. However, in ISO 50001:2018 the requirement for a Management Representative has been removed and only an EnMS Team is required. In the transition to ISO 50001:2018 an organisation who wishes to retain the role of the Management Representative simply needs to make it an EnMS requirement.
Another change concerns documentation. In ISO 50001:2011 there are two categories of documentation:
-
- A specific document required by the Standard
-
- Other documents determined by the organisation to be necessary (Sub Clause 4.5.4.1)
If you listed the documents specifically required by ISO 50001:2011, the list is not very long. Among others, it would include the Energy Policy, the Energy Review, scope and boundaries of the EnMS, and energy objectives, targets and action plans.
This meant it was up to the organisation to decide what other documentation was necessary. For example, in Clause 4.5.2 it states:
The organisation shall identify training needs associated with the control of its significant energy uses and the operation of its EnMS. The organisation shall provide training or take other action to meet these needs.
There is no specific requirement in the standard to document the training needs analysis or any of the training materials. However, if this element was audited, internally or externally, how could an organisation prove it had been done without appropriate documentation?
In ISO 50001:2018 the specific documentation requirement has been reduced even further so an even greater onus is placed on the organisation to determine what documentation is required. This gives more flexibility but it also requires more thought. A key way of approaching documentation is to list all the mandatory requirements within the standard (look for the word “shall”). Then against each requirement ask yourself: “What documentation do I need to show that my organisation has met this specific requirement?”
Going back to the training needs requirement in ISO 50001:2011, this has been removed in ISO 50001:2018. Instead the goal of competency is stated but the means of achieving this is left to the organisation.
6. Additions to Requirements in ISO 50001:2011
6.1 Context of Organisation (Clause 4.1)
Some additional requirements come with the HLS. Clause 4 of ISO 50001:2018 sensibly includes the organisational context (4.1) and understanding the needs and expectations of interested parties. Clause 4.3 addresses scope and boundaries where there is a requirement: “The organisation shall not exclude an energy source within the scope and boundaries”. It is up to the organisation to set its scope and boundaries yet this requirement appears to be instructing an organisation to include all energy sources which appears contradictory. In Clause 3.1.4 under definition of “EnMS Scope” there is Note 1 which says: “The EnMS can include several boundaries and can include transport operations”. Transport is an energy source but the note seems to suggest this is an option (use of the word ‘can’) rather than a requirement. Some may argue this is not contradictory as it all depends on how an organisation defines its scope and boundaries.
The definitions of “boundary” and “EnMS scope” do not add much light:
“boundary” – physical or organisatonal limits
“EnMS Scope” – set of activities, which an organisation addresses through an energy management system
6.2 Leadership (Clause 5.0)
Sensibly the Energy Policy is now Clause 5.2 under Leadership. As mentioned earlier, the requirement of a Management Representative has been removed and only an EnMS Team is required. But every team needs a leader. The senior management role has been increased in ISO 50001:2018. My own feeling is that the management commitment requirement in ISO 50001:2011 was sufficient and, at times, hard to get in large organisations. By increasing this requirement even further then this difficulty will be increased.
6.3 Planning (Clause 6.0)
Clause 6.1 addresses risks and opportunities as a new addition. This is a sensible addition. The rest of Clause 6 is similar to the equivalent requirements of ISO 50001:2011.
6.4 Support (Clause 7.0)
Some minor changes have been made but nothing significant. The dropping of the requirement for a training needs analysis has been mentioned earlier.
The grouping of documentation has largely been included in Clause 7.5 “Documented information”. This is an improvement but the approach to documentation is now more flexible and the advantages/disadvantages of this have been described earlier.
6.5 Operation (Clause 8.0)
This is generally the same as the equivalent requirement in ISO 50001:2018. In Clause 8.3 under ‘Procurement’, there is a statement which states:
Where applicable, the organisation shall define and communicate specifications for:
a) ensuring the energy performance of procured equipment and services
b) the purchase of energy
On point b) how can the specification for the purchase of energy itself impact energy performance? In the case of natural gas and grid electricity, a delivered kWh is a kWh. It has no relevance. In the case of other types of energy, the specification may make an impact on energy performance. Examples include moisture content of liquid and solid fuels, types of biomass, swell index on some solid fuels etc. I accept it does say “where applicable” but some clarification would have been useful in Annex A “Guidance for Use”.
6.6. Performance evaluation (Clause 9.0)
This is now sensibly structured with
-
- monitoring energy performance (9.1)
-
- internal audit (9.2)
-
- management review (9.3)
There is a useful addition to ‘Internal Audit’ which says in Clause 9.2.2:
The organisation shall define the audit criteria and scope for each audit.
This is significant because in ISO 50001:2011 there is no reference to the scope requirement of each internal audit. In its absence, some certification bodies have incorrectly assumed it is a requirement that an internal audit should cover every aspect of the EnMS in every internal audit. This is incorrect because there is no such specific requirement in ISO 50001:2011. So under ISO 50001:2018 this incorrect interpretation has been addressed: it is up to the organisation to define the scope of each internal audit.
The requirements of the management review have been expanded and clarified which is a welcome change.
6.7. Improvement (Clause 10)
Clause 10.1 covers “Nonconformity and corrective action”. The need for ‘preventive action’ has been removed in favour of viewing corrective action in a broader context.
Clause 10.2 “Continual Improvement” is an addition. It only has two sentences. The second is controversial. It says:
The organisation shall demonstrate continual energy performance improvement.
In ISO 50001:2011 there are several references to ‘continual improvement in energy performance’, such as a commitment in the Energy Policy which is continued in ISO 50001:2018. But the controversy hinges in the word “demonstrate” which is new and has been highlighted by Vilnis Vesma. The argument is that if you cannot demonstrate continual improvement in energy performance year-on-year then an organisation is subject to a non-conformance which could affect certification. The argument is that for any organisation, a plateau will be reached, where future improvement in energy performance is impossible without either closing a facility or investing in energy efficiency measures that are not cost effective.
However, this argument is based on a static view of an organisation over time in which neither the organisation nor energy saving technology changes.
My own view is that this requirement contradicts the setting of energy objections and targets which is to be done by the organisation. Sometimes just to maintain savings at their current level requires much effort.
What matters here is how a certification body will interpret this requirement. A pragmatic approach is for an organisation itself to interpret Clause 10.2 and then find a certification body who agrees with them.
7. Timings
ISO 50001:2018 was published in August 2018 but organisations can continue to be certified to ISO 50001:2011 for 18 months (February 2020). For organisations holding ISO 50001:2011 they have three years from publication to migrate to the new standard. So this transition must be completed by August 2021.
For those wishing to use ISO 50001 as a means of compliance with ESOS, they need to hold an accredited certificate on the ESOS compliance date of 5 December 2019. Also the scope of ISO 50001 certification must match the scope of ESOS liabilities. If not, then ISO 50001 will count as a means of partial compliance to ESOS and the shortfall must be made up by other means. For example, if an ESOS assessment requires transport energy to be included but this is not included in the scope of the EnMS then a separate ESOS Transport Energy Audit would be required to meet the shortfall.
Many organisations aiming for certification to ISO 50001 in 2019 will be building their EnMS to ISO 50001:2011 rather than ISO 50001:2018. The reason is that it takes 6 to 8 months from the publication of the new standard for UKAS and certification bodies to get accredited to the new standard. ISO 50001:2018 was published towards the end of August 2018. This means certification bodies will not be in a position to conduct accredited certification audits to ISO 50001:2018 until around March or April 2019. The time scale from when a certification body starts a certification audit to when certification is actually received can be 4 to 6 months. This means the earliest accredited certifications to ISO 50001:2018 will not be till July or August 2019. So it will be possible for organisations to get accredited certification to ISO 50001:2018 by the ESOS December 2019 deadline but I predict most will opt for ISO 50001:2011.