Planning and managing of changes (NEW clause)
What changed in the 2026 revision
Entirely new clause in 2026. Requires a structured, documented approach to plan and manage changes that could affect EMS outcomes. Changes can originate from internal or external sources. Must clearly distinguish emergency situations from abnormal operations. Certification-body analysis: 'This formalization addresses a long standing gap where change management has been inconsistently applied.'
What auditors will look for
Implement a documented Management of Change procedure. This is a NEW requirement — most 2015-era systems will not have this. The procedure should cover: (1) identifying the need for change; (2) assessing potential impacts on EMS outcomes; (3) planning the change with resources and timelines; (4) implementing and verifying.
How to close the gap
- 1Create a Change Request Form (who, what, why, when, environmental impact)
- 2Define an environmental impact assessment checklist for proposed changes
- 3Assign responsibility for change approval (typically senior manager)
- 4Create a change log to track all assessed changes
- 5Link the MoC process to your risk register and aspects register
- 6Test the process with a recent real change as a pilot
- 7Brief all relevant staff on when and how to raise a change request
More changes in Clause 6
Planning your transition timeline? Use the free deadline calculator →