Environmental Aspects and Impacts Register: Method and Checklist

Where should a plant’s environmental aspects analysis start?

With the site and its flows, not with a template. An analysis copied from another sector gives itself away within minutes on the shop floor: it cites aspects that do not exist and misses the ones that matter. Preparation comes down to four moves.

1. Break the site down into activities: receiving, storage, production line by line, cleaning, utilities (boiler, compressors, refrigeration units, electrical substation), maintenance, wastewater treatment plant, packing, dispatch, offices, outdoor areas, and contractors’ work on site.
2. Gather the data: energy bills, water meter readings, discharge analyses, safety data sheets, waste tracking forms and register, site permits, complaints from neighbours, incident reports.
3. Set up a small team: production, maintenance and HSE, with one person accountable for the analysis.
4. Walk the site at different times: during production, during cleaning, during a maintenance job. Abnormal aspects are rarely visible from a meeting room.

For each activity, note what goes in (materials, water, energy, chemicals, packaging) and what comes out (products, liquid discharges, emissions, waste, noise, odours). This double list is the raw material of the analysis.

How do you identify aspects without missing any?

By crossing each activity with three conditions and two levels of control. The conditions are normal, abnormal (start-up, shutdown, maintenance, cleaning, breakdown) and emergency (spill, fire, leak, flood). The level of control separates the aspects you control directly from those you can only influence: hauliers, suppliers, waste collectors, customers.

The questions that bring forgotten aspects to the surface:

• Utilities: how much fuel and electricity, which refrigerant in the cooling units, where do boiler blowdown and compressor condensate go?
• Maintenance: where do used oil, contaminated rags, filters and empty chemical containers go?
• Cleaning: which products, what volumes of water, where does the washing water go?
• Outdoor areas: where does rainwater run off from storage and unloading areas?
• Contractors on site: what waste do they leave, what products do they bring?
• Upstream and downstream: which purchases weigh most, how are products packed and shipped, what happens to them after use?

The last question addresses the life cycle perspective, which the Global ACI transition document classes among the Annex A clarifications of ISO 14001:2026. Finally, add planned changes: a line still at project stage already has its aspects. The changes in the 2026 edition are set out in our guide to ISO 14001:2026 changes.

How do you decide that an aspect is significant?

With criteria written before scoring and applied the same way to every line. The grid below is a working example, to be adapted to your site; it does not come from any official text.

Then set a threshold rule, for example the product of the scores, and override rules that take precedence over the calculation:

• any aspect linked to a compliance obligation is significant;
• any aspect that has led to a complaint or a request from an interested party is significant;
• an emergency situation with high severity is significant, even if it is rare.

Score each aspect before existing controls, or show both scores clearly. A grid that quietly builds controls into the score ends up making everything non-significant, and auditors notice. Each significant aspect must lead to at least one decision: an objective, an operating instruction, monitoring, training or an emergency plan.

How do you build the register of compliance obligations?

With one line per concrete requirement, not one line per law. Obligations come from four sources: laws and decrees, site permits and their conditions, customer requirements, and voluntary commitments. Each line states what the obligation requires on site, the aspect concerned, who owns it, what evidence demonstrates it and how often you check.

Here are sample lines, drafted from the texts listed on the Moroccan Ministry’s pollution page and from the text of Law No. 28-00 on waste management and disposal (loi n° 28-00 relative à la gestion des déchets et à leur élimination) published on the Adala portal of the Moroccan Ministry of Justice (Arabic version consolidated to 30 August 2012, our own translation; only the Official Bulletin is authoritative). The other texts in the table are Decree No. 2-07-253 on waste classification and the list of hazardous waste (décret n° 2-07-253 portant classification des déchets et fixant la liste des déchets dangereux), Law No. 49-17 on environmental assessment (loi n° 49-17 relative à l’évaluation environnementale) and Framework Law No. 99-12, Morocco’s National Charter for the Environment and Sustainable Development (loi-cadre n° 99-12 portant Charte nationale de l’environnement et du développement durable).

The register also covers discharges to water and air emissions: the Ministry’s natural environments page lists, among others, Law No. 36-15 on water (loi n° 36-15 sur l’eau), Decree No. 2-04-553 on direct or indirect discharges, spills and deposits into surface water or groundwater, Law No. 13-03 on combating air pollution (loi n° 13-03 relative à la lutte contre la pollution de l’air) and Decree No. 2-09-631 setting the limit values for pollutant emissions to air from stationary sources and how they are monitored. Each text becomes one or more register lines, written from a reading of the text itself: the requirement that applies to your discharges, the expected evidence of compliance and the frequency of checks.

For Law 49-17, one clarification is needed: its Article 32 makes its entry into force depend on the publication of its implementing texts, at which point it repeals Law No. 12-03, the previous environmental impact assessment law. The register therefore states which of the two laws applies at the date of the last review, with a link to Law 49-17, and this line is checked again at every update. The Framework Law 99-12 can be read in French on the Ministry’s website.

Do not forget non-regulatory obligations: the conditions of your permit, the specifications of an industrial zone, the environmental requirements of a European customer, a commitment made to a lender. They follow the same format. Outside Morocco, the method is identical; only the texts change.

How do you evaluate compliance and keep the register up to date?

By checking each line at the set frequency, evidence in hand, and recording the result. For each line: compliant, noncompliant or not applicable, the date, the evidence examined and, for any gap, a dated action with an owner. The evaluation report is an input to the management review.

The register is updated on triggers, not just once a year:

• a new or amended text picked up by regulatory watch;
• a new permit or a permit renewal;
• a new product, a new waste stream, a new contractor;
• a change on site, reviewed under clause 6.3 of ISO 14001:2026;
• a complaint, an incident, a visit by the environmental police.

The same triggers update the aspects analysis. The two documents live together: an aspect with no linked obligation, or an obligation with no aspect, points to something missed.

Which mistakes should you avoid?

They are almost always the same, and auditors look for them:

• an analysis copied from a template or from another site of the group;
• only normal conditions are analysed;
• indirect aspects (hauliers, waste collectors, purchasing) are missing;
• significance criteria are not written down, or change from one line to the next;
• the score builds in controls to make awkward aspects disappear;
• the register is just a list of laws, with no concrete requirement and no evidence;
• the hazardous waste collector’s licence has never been checked;
• the register has not moved since certification, despite an extension or a new product.

The checklist before presenting the two documents to the auditor:

• Every activity in the scope is in the analysis, maintenance and outdoor areas included.
  
• Each activity is analysed in normal, abnormal and emergency conditions.
  
• Indirect aspects and the life cycle perspective are covered.
  
• Criteria and threshold rules are written, dated and applied to every line.
  
• Each significant aspect has at least one control decision.
  
• Each obligation is translated into a concrete requirement, with owner, evidence and frequency.
  
• Waste contractors’ licences are current and filed.
  
• The latest evaluation of compliance is dated, with its gaps and their actions.
  
• The team knows the update triggers.
  

To see these two documents at work for a European customer, read our ISO 14001 case study of a Moroccan exporter.