MSI's ISO 9001,14001 and 45001 compliance obligation procedure template

Integrated ISO 9001 + ISO 14001 + ISO 45001 Evaluation of Compliance Procedure Template & Guide

$349

Three standards that ask three different questions, held in one register with one evaluation habit and one compliance status picture. Nineteen genuine divergences, separated into differences of depth and differences of kind, every one recorded with the alternative that was available.

Three standards, and they do not line up. ISO 14001 and ISO 45001 both carry an explicit compliance obligations clause at 6.1.3 and an explicit evaluation of compliance clause at 9.1.2 — but ISO 45001 asks for more in nine places. ISO 9001 carries neither clause, and treats statutory and regulatory requirements as requirements for the product rather than obligations of the organization.

Most integrated systems resolve this by running the compliance process off the environmental standard and assuming the other two are covered. They are not. The safety side loses the method determination, the retention duty and the worker consultation requirement. The quality side loses nothing, because it was never in the register to begin with — which is precisely the problem.

Three questions, one register

Standard The question it asks What it provides
ISO 14001:2026 Is what we do lawful where we do it? Register, applicability, frequency, evaluation, status
ISO 45001:2018 Is what we do lawful, and are the people doing it protected as the law requires? All of the above, plus method, retention, update duty and worker consultation
ISO 9001:2015 Is what we supply lawful in the market it goes to? None of it. Statutory and regulatory requirements appear in seven clauses, all about the product

Appendix D — two groups, nineteen divergences

The group headings matter as much as the entries. Separating them shows why each was resolved the way it was; presenting them as one list makes the whole appendix look arbitrary.

Group A — differences of depth Group B — differences of kind
Between ISO 45001 and ISO 14001 ISO 9001 and the other two
What is happening Both ask for the same thing. One asks for more of it ISO 9001 asks a different question and has no compliance clause at all
How many Nine Ten
How it is resolved Take the stricter and apply it to all scopes Extend the mechanism to the scope that has none
What it costs you A little more rigor on the environmental side A register the quality system has never had, and a gate before commitment

Seventeen of the nineteen raise the obligation on at least one scope. That is not an accident of drafting — an integrated system defaults to the strictest requirement in it, and the value of writing them down is being able to reverse one knowingly rather than discovering later that you took it on. Each entry carries the alternative that was available and a place to confirm, followed by eleven decisions to sign off before adoption.

Who this is for

IMS managers running all three standards, and organizations running two who are adding the third. Section 2.1 is a scope determination that comes first, and content is marked throughout for quality, environmental and OH&S scope — so the document works before the third certificate arrives.

The obligation that belongs to all three

A solvent-based coating. The solvent carries a workplace exposure limit, its emissions are subject to a permit condition, and one of its components appears on a restricted substance list applying to the finished product in two of five markets.

Recorded in three places by three functions, the supplier reformulates to improve drying time. The change is assessed for product performance and approved. Nobody assesses it against any of the three duties. The reformulation raises the concentration of the restricted component, changes the emission profile, and alters the exposure characteristics of the vapor.

No two-standard combination would have caught it either. A quality and environmental system misses the exposure limit. A health, safety and environmental system misses the product restriction. Three registers make the connection invisible three times over.

Four determinations, four clocks

When a requirement is found not to be met, four things run in parallel and only one of them is the corrective action. The incident determination, the notification determination and the product-in-market determination are all same-day steps, because their deadlines are measured in hours while a root cause investigation is measured in weeks. Putting them in sequence behind the investigation is the most common way an organization turns a compliance failure into a reporting failure as well.

What is inside

51 pages, 52 tables, every bracketed placeholder a decision you make rather than a blank someone forgot.

What How much of it
Numbered sections 18 — 0.0 Document Control through 17.0 Revision History
Appendices 6 — A, B, C, D, E and F
Integration decision record 9 divergences of depth and 10 of kind, each with the alternative and a place to confirm
Trigger table 18 named triggers, each with the scope, the role that raises it and a time limit
Responsibilities 9 roles, each gating role with a named alternate
Procedure steps 13 numbered steps, 7.1 through 7.13
Evaluation methods 9 methods, each with what it suits and the evidence the record must name
Exception paths 12 cases, each with what happens and an owner
Records table 16 records, each with owning role and retention period
Process interfaces 13 interfaces, what flows in and what flows out
Key performance indicators 10 indicators with target and owner
Maturity ladder 8 elements, 4 levels each, described as observable behavior
Clause cross-reference 37 rows, every obligation mapped to every standard
Compliance obligations register 32 fields, ready to use as a spreadsheet
Compliance evaluation record 16 fields
Nonfulfillment action record 20 fields
Worked examples 2, deliberately different in shape
Auditor questions answered 15, each with where in the document the answer is
Determination worksheet 5 parts, to be completed before the procedure runs
Process interaction map Included — required by ISO 9001 Clause 4.4.1

Why this is not the clause reworded

Every procedure Management Systems International publishes is built to seven structural marks. Most procedures in circulation satisfy four or five, and the ones they miss are almost always the same ones.

  • A real trigger — enumerated channels, including the informal route somebody actually uses
  • One accountable owner — with a named alternate for every gating role
  • Stated decision criteria — four factors and standing rules that fix a frequency, not intentions
  • Records as a byproduct — the register and the evaluation record are the work, not a report about it
  • A defined exception path — including the one where commercial pressure demands a commitment before the obligations are known
  • Trainable in one sitting — a desk-level work instruction with two worked examples
  • A built-in review trigger — event-based, with the calendar as backstop only

Also available

Single-standard variants of this procedure are published for ISO 14001:2026, ISO 45001:2018 and ISO 7101:2023. Two-standard variants cover ISO 14001 with ISO 45001, and ISO 9001 with ISO 14001.

Common questions

Why nineteen divergences and not one list?

Because there are two genuinely different kinds. Nine are differences of depth: ISO 45001 and ISO 14001 ask for the same thing and one asks for more — a method as well as a frequency, retention as well as availability. Ten are differences of kind: ISO 9001 has no compliance obligations clause and no evaluation of compliance clause at all, so the question is not how much but whether a mechanism exists. Presenting them as one list makes the resolution look arbitrary.

What are the three questions?

ISO 14001 asks whether what you do is lawful where you do it. ISO 45001 asks whether what you do is lawful and whether the people doing it are protected as the law requires. ISO 9001 asks whether what you supply is lawful in the market it goes to. The first two are organizational questions with the same shape. The third is a product question with a different determination point and different evidence.

Does ISO 9001 have an evaluation of compliance clause?

No. It carries statutory and regulatory requirements in seven clauses and every one of them is about the product or service. There is no register, no applicability determination, no evaluation frequency, no evaluation method and no compliance status anywhere in the standard.

What are the two decisions worth arguing about?

A-6 and B-6. A-6 extends ISO 45001 clause 5.4 d) 4) — consulting non-managerial workers on how legal requirements are fulfilled — to environmental and product obligations, which neither of those standards requires. B-6 extends the whole compliance mechanism to a scope whose standard asks for none of it. Together they are what makes this an integrated compliance process rather than three processes filed together, and together they are most of the additional work.

What is a multi-scope obligation?

A single duty attaching in more than one scope. A solvent carries a workplace exposure limit, an emission condition and a substance restriction in the destination market — three duties, three functions, one material. Recorded separately it is evaluated three times and owned by nobody. One register makes it one row with three marks and a single owner.

Why does an integrated system need this more than a single-standard one?

Because the shared inputs are where the failures live. Worked example one in the template follows a coating reformulation that breaks all three duties at once — and note that no two-standard combination would have caught it either. A quality and environmental system misses the exposure limit; a health, safety and environmental system misses the product restriction.

How many management review inputs does this produce?

Six. Each of the three standards asks separately what changed in the obligations, and separately how the organization performed against them. A review reporting one compliance percentage has answered one-sixth of what the three standards ask, and the change inputs are where a new duty with an implementation deadline would have surfaced.

Can we use it if we run two of the three now and are adding the third?

Yes, and that is the case it is best suited to. Content is marked throughout for quality, environmental and OH&S scope, and section 2.1 is a scope determination that comes before anything else. Building to all three and using part of it is substantially easier than retrofitting a register later, because retrofitting means revisiting every applicability determination already made.

Does it include a process interaction map?

Yes. ISO 9001 Clause 4.4.1 requires the organization to determine the processes needed and their sequence and interaction; neither ISO 14001 nor ISO 45001 has an equivalent requirement. The map is included along with the full interface table it depicts.

Is evaluation of compliance the same as an internal audit?

No, in any of the three standards. Clause 9.2 asks whether the management system conforms and is effectively implemented. Clause 9.1.2 asks whether you are meeting your obligations. They can be scheduled together but they produce separate results and separately retained evidence.

What format is it, and can we rebrand it?

Editable Microsoft Word (.docx). Purchase grants your organization a perpetual, non-exclusive license to edit, rebrand and adopt it, including at multiple sites under common ownership. It may not be resold or distributed outside your organization.

Building the quality side of this? The QMS Interviews course covers how to get accurate answers out of the people who actually run the process.

Already certified to ISO 14001:2015? The ISO 14001:2026 Transition course walks the changes clause by clause. Relevant only if you hold a current 2015 certificate.

Not sure where your process actually sits? Take the free Compliance Evaluation Maturity Check at msi-international.com. Eight elements, under five minutes, score shown immediately.

Want help implementing it? Call Management Systems International at 760-434-9141 to schedule a planning session.

About Management Systems International

Management Systems International is a veteran-owned, female-owned ISO consulting firm founded in 1998. Across 28 years we have supported 80+ certifications, attended 200+ audits alongside our clients, and trained 600+ professionals across manufacturing, technology, medical device, government, healthcare, and other regulated industries.

We write these templates the way we write procedures for clients: as finished, worked documents with the judgment calls already made and explained, so you can see what a decided position looks like before you make your own.


Perennia Corp is a fictional company used for illustration throughout the template, and is not connected with any real organization of the same or a similar name. This is a template and guide, not certification or legal advice. Your compliance obligations are yours to determine, and unfilled placeholders are unmet requirements.

ISO 9001, ISO 14001 and ISO 45001 are trademarks of the International Organization for Standardization. This template is an independent work by Management Systems International, LLC and is not endorsed by or affiliated with ISO or any certification body. None of the standards is reproduced in the template.

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