Is there a distinction between “consider” and “take into account” in ISO 14001:2015?

Posted on Posted in Terminology

Yes – there is a distinction – maybe.

In some places in ISO 14001:2015, the word “consider” is used; in other places the phrase “take into account” is used.  In a few instances, both are used.

For example –

  • In Clause 4.3, the standard states that the organization shall consider external and internal issues in determining the scope of its environmental management system (among other factors).
  • In Clause 6.1.2, the standard states that the organization shall take into account change, abnormal conditions and reasonably foreseeable emergency situations in determining its environmental aspects.
  • In Clause 6.2.1, the standard states that the organization shall establish environmental objectives at relevant functions and levels, taking into account the organization’s significant environmental aspects and associated compliance obligations and considering its risks and opportunities.

According to the explanation provided in the Annex – When the standard uses the term consider, it means that it is necessary to think about the topic but it can be excluded.  When the standard uses the phrase take into account, the topic must be thought about and cannot be excluded. (This is the clause A.3).

What is not clearly explained is what ” not excluded” refers to.

  • Is it “not excluded” from the process?
  • Is it “not excluded” from the determination (i.e. the analysis)?
  • Does “not excluded” mean that it must be included or addressed?

For example, does 6.2.1 mean that an organization must analyze the need for environmental objectives for each significant environmental aspect (it is included in the determination) or does it mean that the organization must have an environmental objective for each significant environmental aspect?

(For ISO 14001:2004  which had similar language, the interpretation was that only an assessment of the need was required – an objective was NOT required for each significant environmental aspect.)

If the requirement is only that the factor be included in the assessment, what is the actual difference between consider and take into account?

Interestingly, according to the dictionary and the internet, these phrases mean exactly the same thing.