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ISO 14001Internal audit

ISO 14001 internal audit: approach and checklist per clause

An internal audit is a mandatory part of ISO 14001  (clause 9.2). With it, you check for yourself whether your environmental management system meets the standard and works in practice. The internal audit is your last check before the external auditor arrives, and at the same time a tool for continual improvement. The official text of the standard is available from NEN . Below you will find the approach, a practical checklist per clause, and how to decide whether to audit yourself or outsource. See also the page the audit process for ISO 14001 for how the external audit runs.

Why an internal audit is mandatory

Clause 9.2 states that you carry out internal audits at planned intervals. The purpose: to determine whether the environmental management system meets the requirements of the standard and your own requirements, and whether it is effectively implemented and maintained.

The standard also sets out three conditions:

  • you create an audit programme (a schedule over time)
  • your auditors are objective, they do not check their own work
  • you report findings to management and follow them up

The internal audit does not replace the external certification audit. It is an internal control tool. But a thorough internal audit considerably reduces the risk of surprises during the external audit.

The approach in five steps

Plan the audit programme

Draw up an audit programme for the year. Which clauses do you audit when? Over a three-year period, all clauses should be covered. Typically you audit the critical clauses (environmental aspects, compliance, objectives) every year.

Record the programme in a simple schedule: date, topic to be audited, auditor, department involved.

Set the audit criteria and scope

Before you start, decide what you will check and against which criteria. The criteria are the requirements of ISO 14001, but also your own procedures and work instructions. The scope is the boundary: which department, site or process step do you check?

Carry out the audit

An internal audit consists of three parts: document review, interviews, and a walk-through of the site.

During the document review, you check whether procedures and records are complete, up to date and consistent. In interviews, you talk to employees: do they know the environmental policy, do they know what their role is, and how do they deal with environmental aspects in their daily work? During the walk-through, you check whether reality matches what is documented.

Document findings

Note conformities (it is correct), observations (points for improvement without a non-conformity), and non-conformities (the standard or your own requirement is not being met). Use the same terminology as the external auditor.

For each non-conformity, note: the standard clause, the description of the non-conformity, and the evidence (what did you see or find?).

Follow up on findings

Set non-conformities as corrective actions. For each one: what is the cause, which action solves it, who is responsible, and when is it done? Keep the report and the follow-up actions for the external auditor. The structure of such a report, with a completed example, is on internal audit report for ISO 14001.

ISO 14001 internal audit checklist per clause

Use this checklist during your internal audit. Each row shows what you check, which documents you review, and which questions you ask.

Clause 4: Context

CheckpointWhat you checkQuestions for employees
Context analysis present and up to dateDocument with internal and external factors”Have there been changes that affect the context analysis?”
Stakeholders and their requirements documentedStakeholder overview”What new requirements have customers or regulators raised?”
Scope defined and realisticScope document”Do all activities with an environmental impact fall within the scope?”

Clause 5: Leadership

CheckpointWhat you checkQuestions for employees
Environmental policy signed and up to datePolicy statement, date, signature of management”Do you know what the environmental policy says?”
Policy communicatedEvidence of communication (email, poster, toolbox meeting)“Is the policy available to everyone?”
Management shows commitmentMinutes of management review, resources made available”How does management actively support the system?”

Clause 6: Planning

CheckpointWhat you checkQuestions for employees
Environmental aspects register completeRegister with aspects, impacts and significance assessment”Are there new activities or processes that are not in the register?”
Significance assessment transparentCriteria recorded, assessment per aspect traceable”How was it decided that this aspect is significant?”
Compliance register up to dateList of laws and regulations per environmental aspect”Are there new laws or permit requirements?”
Compliance evaluation carried outEvidence that you checked per obligation whether you comply”How do you know you comply with the requirements of the Environment and Planning Act (Omgevingswet)?”
Environmental objectives measurable and monitoredObjectives plan with progress”How do you measure progress on your environmental objectives?”

Clause 7: Support

CheckpointWhat you checkQuestions for employees
Competences defined and securedTraining matrix, training records”What training did you complete for your environmental tasks?”
Awareness demonstratedEmployees can name the environmental policy and their own role”What does your department contribute to the environmental objectives?”
Documented information controlledVersion control, accessibility, no outdated versions in circulation”Where do you find the current procedures?”

Clause 8: Operation

CheckpointWhat you checkQuestions for employees
Operational control measures in placeInstructions, procedures per significant aspect”How do you deal with [specific environmental aspect] in your daily work?”
Emergency plan in place and testedEmergency plan, report of exercise or incident”Do you know what to do in case of a leak or fire?”

Clause 9: Performance evaluation

CheckpointWhat you checkQuestions for employees
Measurement data availableEnergy, waste and emissions data over the measurement period”How is measurement data recorded?”
Objectives are monitoredProgress reports”How do you know whether you are on schedule?”
Management review heldMinutes with the required inputs and outputs”When was the last management review?”

Clause 10: Improvement

CheckpointWhat you checkQuestions for employees
Non-conformities recorded and followed upNon-conformity register, corrective actions with status”How do you report a non-conformity or incident?”
Improvements demonstrableComparison of performance over time”What improvements were achieved in the past year?”

Make sure your checklist is not just a list of ticks. An auditor who only ticks off documents and does not talk to employees or walk around misses half the picture. The combination of document review, interviews and a site walk-through makes an audit valuable.

Audit yourself or outsource?

ConsiderationAudit yourselfOutsource
CostsLower (time only)Higher (€500-€2,500 per day)
ObjectivityRisk of tunnel visionFresh outside perspective
AvailabilityDepends on internal capacityCan be planned
Knowledge of the standardRequires training or experienceExternal auditor is a specialist
Small organisationsOften difficult due to limited separation of dutiesLogical choice
Combined auditsEasy to combine with ISO 9001External auditor can do both

The golden rule: an auditor may not check their own work. If the environmental coordinator made the environmental aspects analysis, that same person may not audit that analysis internally.

At small companies, this creates a practical problem. Solutions are: train a colleague from another department as an internal auditor, hire an external internal auditor, or rotate the audit task.

An external internal audit typically takes half a day to a full day for a small company. The costs range from €400 to €1,500, depending on the size. See the costs and timeline for more cost overviews.

Frequency and recording in the audit programme

The standard asks for periodic internal audits but does not prescribe a frequency. In practice, for certification tracks, at least one full internal audit per year applies.

Draw up an audit programme that looks at least three years ahead. For each audit, record:

  • which clauses or processes are audited
  • who the auditor is
  • when it takes place
  • how findings are followed up

The external auditor will ask for this programme. An incomplete or unfollowed programme is a finding.

Next step

After the internal audit, the process continues with the management review and then the external certification audit. Read the complete step-by-step plan or see what the external auditor expects on the page the audit process for ISO 14001.