ISO 14001:2026 for Auditors > Clause 7.2
Explained: Competence
Clause 7.2 of ISO 14001 asks an organisation to ensure that people doing work under its control are competent where their work can affect environmental performance or compliance obligations. In plain English, this means people must have the right knowledge, skills, training or experience to do environmentally important work properly.
What is ISO 14001 Clause 7.2 trying to achieve?
Clause 7.2 is about making sure people are capable of carrying out work that can affect the Environmental Management System.
The organisation should identify what competence is needed, ensure relevant people have that competence, take action where competence is lacking, and retain appropriate evidence.
The purpose is not simply to collect training certificates. The purpose is to make sure people can perform their environmental responsibilities effectively.
Why competence matters in an EMS
Many environmental problems happen because someone did not know what to do, misunderstood a requirement, lacked practical skill, or was given a responsibility without proper support.
Competence can affect:
- chemical handling and storage;
- waste segregation and disposal;
- spill response;
- equipment maintenance;
- monitoring and measurement;
- compliance obligations;
- contractor control;
- emergency preparedness;
- internal auditing;
- environmental reporting;
- management review and decision-making.
A person does not need to be an environmental specialist for every task. But they do need to be competent for the environmental responsibilities they actually have.
What does ISO 14001 expect?
ISO 14001 expects the organisation to determine the competence needed for people doing work under its control that affects environmental performance or compliance obligations.
The organisation should then:
- ensure those people are competent;
- base competence on suitable education, training or experience;
- take action to gain the necessary competence where needed;
- evaluate whether those actions are effective;
- retain appropriate documented information as evidence of competence.
This applies not only to employees. It may also apply to temporary workers, agency staff, contractors, consultants or external providers where they do work under the organisation’s control.
Competence is broader than training
Training is one way to build competence, but it is not the only way.
Competence may come from:
- formal education;
- vocational qualifications;
- professional certification;
- on-the-job training;
- supervised practice;
- coaching or mentoring;
- previous experience;
- role-specific instruction;
- competence assessment;
- refresher training.
Auditors should avoid assuming that a training record automatically proves competence. A person may have attended training but still be unable to apply it properly.
Simple example
A worker may have completed spill-response training, but competence is better demonstrated if they can explain where the spill kits are, how to use them, how to protect drains, who to notify and what records are needed after an incident.
People doing work under the organisation’s control
Clause 7.2 applies to people doing work under the organisation’s control. This may include more than direct employees.
Depending on the organisation, it may include:
- full-time employees;
- part-time employees;
- temporary or agency workers;
- contractors;
- maintenance providers;
- cleaning contractors;
- waste contractors working on site;
- consultants;
- drivers or logistics providers operating under site rules;
- people carrying out monitoring, inspection or audit activities.
The key question is whether the person’s work can affect environmental performance or compliance obligations.
Determining competence needs
The organisation should first determine what competence is needed for relevant roles or activities.
This may be based on:
- significant environmental aspects;
- compliance obligations;
- operational controls;
- emergency response requirements;
- monitoring and measurement tasks;
- contractor control requirements;
- internal audit responsibilities;
- environmental objectives;
- risks and opportunities;
- changes to processes, equipment or legal requirements.
A practical competence process starts by asking: what environmentally important tasks do people carry out, and what do they need to know or be able to do?
Examples of EMS competence needs
EMS competence needs vary by organisation, but common examples include:
- waste segregation and waste documentation;
- chemical storage and handling;
- spill response and emergency procedures;
- operation of pollution-control equipment;
- environmental monitoring and measurement;
- legal compliance evaluation;
- maintenance of tanks, bunds, interceptors or extraction systems;
- contractor induction and supervision;
- internal auditing;
- environmental data collection and reporting;
- management review and performance evaluation;
- procurement decisions affecting environmental performance.
Competence needs should be proportionate. A person making strategic EMS decisions needs different competence from a worker segregating waste or a contractor carrying out maintenance.
Taking action to achieve competence
If competence is lacking, the organisation should take action.
Actions may include:
- training;
- refresher training;
- supervision;
- mentoring;
- toolbox talks;
- contractor briefings;
- competence assessments;
- reallocation of responsibilities;
- recruitment of competent personnel;
- use of external specialists;
- updating procedures or instructions;
- providing clearer information or resources.
The action should match the competence gap. Sending someone on a generic course may not solve a very specific operational issue.
Evaluating effectiveness
ISO 14001 expects the organisation to evaluate whether competence-related actions have been effective.
This means asking: did the action actually improve competence?
Effectiveness may be evaluated through:
- observation of work being carried out;
- questioning employees or contractors;
- competence assessments;
- practical demonstrations;
- audit findings;
- inspection results;
- incident or near-miss trends;
- quality of records produced;
- supervisor feedback;
- repeat performance checks.
Auditor tip
If someone has received environmental training, ask how the organisation knows the training worked. Evidence of attendance is useful, but it is not the same as evidence of effective competence.
Documented evidence of competence
The organisation should retain appropriate documented information as evidence of competence.
This may include:
- training records;
- competence matrices;
- qualification records;
- certificates;
- induction records;
- toolbox talk records;
- assessment records;
- supervision records;
- authorisation records;
- contractor competence evidence;
- audit records showing competence in practice;
- records of refresher training or re-assessment.
The amount of evidence needed should reflect the environmental risk and importance of the role.
Competence and internal auditors
Internal auditors also need to be competent.
An EMS internal auditor should normally understand:
- the purpose and structure of ISO 14001;
- environmental aspects and impacts;
- compliance obligations;
- audit principles and evidence gathering;
- audit planning, scope and criteria;
- interviewing and observation techniques;
- how to identify conformity and nonconformity;
- how to write clear audit findings;
- how to behave objectively and professionally.
Auditor competence may come from formal training, supervised audits, experience, mentoring and periodic review of audit performance.
Competence and contractors
Contractors can create significant environmental risks, especially where they work on site or carry out activities under the organisation’s control.
Contractor competence may matter for:
- maintenance work;
- waste handling;
- chemical delivery or storage;
- cleaning activities;
- construction or refurbishment work;
- servicing of environmental equipment;
- emergency response support;
- transport or logistics activities.
The organisation should decide what competence evidence is needed from contractors and how contractors will be briefed, supervised or controlled.
Practical implementation guidance
A practical EMS competence process may include:
- identifying roles that affect environmental performance or compliance obligations;
- defining competence requirements for those roles;
- checking existing competence;
- identifying gaps;
- planning training or other actions;
- evaluating effectiveness;
- retaining evidence;
- reviewing competence needs when the EMS changes.
Competence should not be treated as a one-off exercise. It should be reviewed when people change roles, processes change, incidents occur, audits identify weaknesses, or compliance obligations change.
What auditors typically look for
Auditors look for evidence that competence needs have been determined and that relevant people are competent for their EMS responsibilities.
Evidence may include:
- competence matrix;
- role profiles or job descriptions;
- training plans;
- training records;
- qualifications or certificates;
- induction records;
- contractor approval records;
- competence assessments;
- records of supervised work;
- audit findings linked to competence issues;
- management review records;
- interviews with workers, managers and contractors.
Auditor tip
Follow the environmental risk. If waste handling, chemical storage or emergency response is important, check whether the people involved are competent and can demonstrate what they need to know.
Common weaknesses in Clause 7.2
- training records exist, but competence needs have not been defined;
- competence is assumed based on job title;
- contractor competence is not checked;
- training is delivered but effectiveness is not evaluated;
- new starters or temporary workers miss environmental induction;
- people are unaware of compliance obligations affecting their work;
- significant environmental aspects are controlled by people without suitable competence;
- competence records are incomplete or out of date;
- internal auditors have not been trained or supervised adequately;
- competence needs are not reviewed after changes, incidents or audit findings.
Weak example
“All employees receive environmental awareness training during induction.”
This is weak if the organisation has not determined role-specific competence needs, checked whether people can apply the training, or addressed competence requirements for higher-risk tasks.
Better example
“The organisation has identified EMS competence requirements for roles affecting environmental performance and compliance obligations. Competence is based on training, experience, assessment and supervision. Effectiveness is evaluated through observation, audit findings, incident trends and supervisor review.”
This is stronger because it shows competence being managed as an EMS process, not just a training record collection.
Real-world example: chemical storage
A site stores chemicals that could cause land or water pollution if mishandled.
Relevant competence needs may include:
- safe storage and segregation;
- understanding bunding and containment requirements;
- recognising leaks or damaged containers;
- using spill kits correctly;
- protecting drains and watercourses;
- reporting incidents;
- retaining inspection records;
- understanding emergency response arrangements.
An auditor could test competence by reviewing training records, observing storage arrangements and asking workers what they would do if they found a spill.
Real-world example: office-based organisation
An office-based organisation may have simpler competence needs, but Clause 7.2 still applies.
Relevant competence may include:
- understanding waste and recycling arrangements;
- following procedures for IT equipment disposal;
- collecting travel or energy data accurately;
- applying procurement requirements;
- understanding environmental objectives;
- carrying out internal EMS audits;
- reviewing environmental performance data.
Competence should be proportionate to the organisation’s environmental aspects and compliance obligations.
Auditor questions for ISO 14001 Clause 7.2
- How does the organisation determine EMS competence needs?
- Which roles can affect environmental performance or compliance obligations?
- What competence is needed for those roles?
- How does the organisation ensure people are competent?
- Is competence based on education, training, experience or another suitable basis?
- What action is taken when competence gaps are identified?
- How is the effectiveness of competence actions evaluated?
- What documented evidence of competence is retained?
- How is contractor competence checked where relevant?
- How are internal auditors trained or assessed?
- How are competence needs reviewed after changes or incidents?
- Can people demonstrate the competence needed for their EMS responsibilities?
Related ISO 14001 clauses
- Clause 5.3 — Roles, responsibilities and authorities
- Clause 6.1.2 — Environmental aspects
- Clause 6.1.3 — Compliance obligations
- Clause 6.1.5 — Planning action
- Clause 7.1 — Resources
- Clause 7.3 — Awareness
- Clause 7.4 — Communication
- Clause 8.1 — Operational planning and control
- Clause 8.2 — Emergency preparedness and response
- Clause 9.2 — Internal audit
- 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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