ISO 14001:2026 for Auditors > Clause 10
Explained: Improvement
Clause 10 of ISO 14001 is about improving the Environmental Management System. In plain English, this means the organisation must continually improve the EMS, respond properly to nonconformities, take effective corrective action, and use what it learns to enhance environmental performance.
What is ISO 14001 Clause 10 trying to achieve?
Clause 10 is about making sure the EMS learns and improves.
Earlier clauses help the organisation plan, support, operate and evaluate the EMS. Clause 10 asks what the organisation does with what it learns.
Clause 10 covers two areas:
- Clause 10.1 — continual improvement;
- Clause 10.2 — nonconformity and corrective action.
The purpose is to ensure that the EMS does not become static. It should use evidence, findings, incidents, trends and decisions to become more suitable, adequate and effective over time.
Why improvement matters in an EMS
An EMS should not stand still.
The organisation should use evidence from audits, incidents, monitoring, compliance evaluation, management review, complaints and operational performance to improve.
Without effective improvement:
- the same nonconformities repeat year after year;
- corrective actions fix symptoms but not causes;
- environmental objectives lose momentum;
- compliance risks remain unresolved;
- lessons from incidents are not learned;
- top management receives information but no meaningful action follows;
- the EMS becomes stale, ceremonial and increasingly irritating to everyone involved.
Clause 10 helps keep the EMS alive, useful and capable of supporting better environmental performance.
How Clause 10 fits into the EMS
Clause 10 sits mainly in the “Act” part of Plan–Do–Check–Act.
It takes inputs from the rest of the EMS, including:
- Clause 6.1 — actions to address risks and opportunities;
- Clause 6.2 — environmental objectives;
- Clause 8.1 — operational planning and control;
- Clause 8.2 — emergency preparedness and response;
- Clause 9.1 — monitoring, measurement, analysis and evaluation;
- Clause 9.1.2 — evaluation of compliance;
- Clause 9.2 — internal audit;
- Clause 9.3 — management review.
It then feeds improvement back into planning, support, operation and performance evaluation.
Auditors should see Clause 10 as the EMS learning loop. It checks whether the organisation improves as a result of evidence, problems, changes and opportunities.
Clause 10.1 — Continual improvement
Clause 10.1 requires the organisation to continually improve the suitability, adequacy and effectiveness of the EMS in order to enhance environmental performance.
In practical terms, this means the organisation should:
- use performance evaluation results to identify improvement opportunities;
- consider outputs from internal audit and management review;
- learn from nonconformities and corrective actions;
- implement actions needed to achieve the EMS intended outcomes;
- improve the EMS in a way that supports better environmental performance.
Continual improvement does not mean everything must improve at once, every month, forever, until everyone collapses under a mountain of action plans. It means the EMS should improve over time in a planned, evidence-based and proportionate way.
Read the detailed SQMC guide to continual improvement.
Clause 10.2 — Nonconformity and corrective action
Clause 10.2 asks the organisation to react to nonconformities and take corrective action where needed.
A nonconformity is a failure to meet a requirement. In an EMS, that requirement may come from ISO 14001, the organisation’s own procedures, compliance obligations, operational controls, customer requirements or other commitments.
Examples include:
- missing waste transfer records;
- spill kits not inspected as required;
- employees not following waste segregation rules;
- environmental objectives not monitored;
- emergency drills not carried out where planned;
- compliance evaluation not completed;
- obsolete EMS procedures still in use;
- contractors not briefed on site environmental requirements;
- corrective actions overdue or ineffective.
Read the detailed SQMC guide to nonconformity and corrective action.
Correction, corrective action and continual improvement
These terms are related, but they are not the same.
Correction deals with the immediate problem.
Corrective action addresses the cause of the problem to reduce the chance of recurrence or occurrence elsewhere.
Continual improvement is the recurring activity of enhancing EMS performance over time.
Simple example
If waste is found in the wrong skip, the correction may be to remove and segregate it properly. Corrective action may involve finding out why it happened and improving signage, training or supervision. Continual improvement may involve redesigning the waste area to make correct segregation easier and then using that learning at other sites.
Improvement should be evidence-based
ISO 14001 improvement should be based on evidence, not guesswork.
Useful sources of improvement evidence include:
- audit findings;
- environmental performance trends;
- incident and near-miss records;
- complaints and interested party feedback;
- compliance evaluation results;
- management review outputs;
- monitoring and measurement results;
- corrective action effectiveness checks;
- changes in context, obligations, risks and opportunities.
Auditors should look for a clear trail from evidence to action to improvement.
Improvement and environmental performance
ISO 14001 links continual improvement with enhanced environmental performance.
This means improvement should not only make the paperwork tidier. It should, where relevant, improve the organisation’s environmental outcomes.
Examples include:
- reducing waste sent to landfill;
- improving recycling quality;
- reducing energy consumption;
- reducing fuel use or transport emissions;
- reducing spills or environmental incidents;
- improving compliance with permit or licence conditions;
- improving contractor environmental performance;
- reducing water consumption;
- improving emergency preparedness;
- improving the reliability of EMS data.
Administrative improvement can still be valuable, but auditors should consider whether the EMS is also helping improve environmental performance.
Improvement can be small and practical
Improvement does not always mean a major project or capital investment.
It may include small, practical improvements such as:
- clearer waste labels;
- better spill-kit locations;
- simpler inspection forms;
- more relevant audit questions;
- better contractor induction content;
- more reliable monitoring data;
- improved communication of objectives;
- more useful management review actions;
- better evidence retention;
- shorter corrective action timescales.
The key is that the EMS is becoming more suitable, adequate and effective over time.
What auditors typically look for in Clause 10
Auditors look for evidence that the organisation identifies improvement opportunities, responds properly to nonconformities, takes suitable corrective action and improves the EMS.
Evidence may include:
- nonconformity records;
- corrective action records;
- root cause analysis records;
- incident investigation records;
- audit findings and follow-up actions;
- management review action logs;
- objective progress records;
- performance trend data;
- records of improvement projects;
- evidence of actions completed;
- effectiveness reviews;
- updated procedures, controls, training or resources.
Auditor tip
Pick one nonconformity or improvement action and follow it from issue to outcome. Was the problem corrected? Was the cause considered? Was action taken? Was effectiveness reviewed? Did the EMS improve?
Common weaknesses in Clause 10
- nonconformities are corrected but root causes are not addressed;
- corrective actions are vague or overdue;
- the same findings repeat year after year;
- effectiveness of corrective action is not checked;
- incidents are recorded but not properly investigated;
- management review identifies actions but they are not completed;
- improvement opportunities are discussed but not implemented;
- environmental performance does not improve and no explanation is recorded;
- corrective action focuses on blaming individuals rather than fixing system weaknesses;
- records do not show what was done or whether it worked.
Weak example
“When problems are found, the organisation fixes them and records the action.”
This is weak because it does not show whether causes are reviewed, corrective action is appropriate, effectiveness is evaluated, or the EMS improves as a result.
Better example
“The organisation records nonconformities, corrects immediate issues, investigates causes where needed, implements corrective actions, checks effectiveness and uses trends from audits, incidents, compliance evaluation and management review to identify continual improvement opportunities.”
This is stronger because it shows improvement as a structured EMS process.
Real-world example: repeated waste segregation issue
An internal audit finds repeated contamination in recycling bins.
A weak response would be to remove the wrong waste and remind staff to “be more careful”.
A stronger Clause 10 response may include:
- correcting the immediate waste segregation issue;
- investigating why the wrong waste was placed in the bins;
- identifying unclear signage and poorly positioned bins as causes;
- updating signage and bin locations;
- briefing employees and cleaners;
- checking contamination rates after the change;
- reporting results during management review;
- using the lesson to improve waste controls at other sites.
This shows correction, corrective action and continual improvement working together.
Real-world example: emergency drill weakness
A spill drill shows that employees cannot find the drain covers quickly.
The organisation responds by:
- recording the drill weakness as a nonconformity or improvement action;
- relocating drain covers closer to the risk area;
- adding clearer signage;
- updating the emergency response plan;
- briefing relevant employees and contractors;
- retesting the response later;
- reviewing the outcome during management review.
This shows how Clause 10 links directly to emergency preparedness, awareness, documented information and management review.
Auditor questions for ISO 14001 Clause 10
- How does the organisation continually improve the EMS?
- How does the organisation identify improvement opportunities?
- How are improvement actions selected and implemented?
- How are nonconformities recorded and managed?
- How does the organisation react when a nonconformity occurs?
- How are immediate corrections handled?
- How does the organisation decide whether corrective action is needed?
- How are causes of nonconformities determined?
- How does the organisation check whether similar nonconformities exist or could occur elsewhere?
- How are corrective actions planned and implemented?
- How is corrective action effectiveness reviewed?
- How are repeat findings or recurring issues handled?
- How does management review contribute to continual improvement?
- What evidence shows improvement in EMS effectiveness or environmental performance?
Related ISO 14001 clauses
- Clause 6.1 — Actions to address risks and opportunities
- Clause 6.2 — Environmental objectives
- Clause 7.2 — Competence
- Clause 7.3 — Awareness
- Clause 7.5 — Documented information
- Clause 8.1 — Operational planning and control
- Clause 8.2 — Emergency preparedness and response
- Clause 9.1 — Monitoring, measurement, analysis and evaluation
- Clause 9.1.2 — Evaluation of compliance
- Clause 9.2 — Internal audit
- Clause 9.3 — Management review
- Clause 10.1 — Continual improvement
- Clause 10.2 — Nonconformity and corrective action
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This page is part of SQMC’s ISO 14001:2026 guidance library for auditors, managers and QHSE professionals.
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