Nonconformity or improvement opportunity?

ISO 14001-2015 : 6 Planning : 6.1 Actions to address risks and opportunities : 6.1.2 Environmental aspects
It was noticed there were no specific criteria being developed to determine significant aspects (Procedure EMS 6.1.2.1) when it impact with legal requirement. Single matrix evaluation considered for both legal and non-legal impacts. It is recommended to look for options to differentiate the two aspects and deals separately.

Answer:
As a consultant I would recommend considering the difference between environmental aspects linked to legal requirements when evaluating significance.

As an auditor I would also recommend the change as an improvement opportunity. As an auditor I would consider the situation as a non-conformity if I found any evidence of not considering any relevant legal requirement attached to an environmenta l aspect. Even if the organization has not included the difference in the evaluation procedure, perhaps in practice is doing it.

The following material will provide you information about an environmental management system:
- ISO 14001 – 4 steps in identification and evaluation of environmental aspects - https://advisera.com/14001academy/knowledgebase/4-steps-in-identification-and-evaluation-of-environmental-aspects/
- List of ISO 14001 implementation steps - https://advisera.com/14001academy/blog/2019/08/27/key-iso-14001-benefits-to-customers/nowledgebase/list-of-iso-14001-implementation-steps/
- free online training ISO 14001:2015 Foundations Course - https://advisera.com/training/iso-14001-internal-auditor-course/
- book - THE ISO 14001:2015 COMPANION – A A Straightforward Guide to Implementing an EMS in a Small Business - https://advisera.com/books/the-iso-14001-2015-companion/