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For companies subject to the requirement to conduct an energy audit, a question arises: should they comply with this obligation or implement an ISO 50001 certification process and thereby "avoid" the energy audit?
Energy audit
Introduced by Law No. 2013-619 of July 16, 2013, to transpose Directive 2012/27/EU on energy efficiency, theenergy audit is mandatory for all companies with more than 250 employees or those exceeding certain criteria in terms of turnover (over 50 million euros) or balance sheet total (over 43 million euros). The energy audit must be carried out every 4 years.
The energy audit consists of an examination and analysis of energy usage and consumption to identify potential improvements in energy efficiency. The energy-saving measures recommended in the audit report are ranked according to a hierarchy of energy efficiency improvement opportunities, distinguishing between operations with a quick return on investment and those with a longer one (between 1 and 4 years or more).
These audits can be performed by external auditors whose competence has been recognized by a COFRAC-accredited body, or by internal company auditors, provided they meet the independence and qualification criteria set out in the decree of November 24, 2014. Failure to conduct this energy audit may result in a formal notice, which may be made public, followed by an administrative fine of up to 2% of turnover (4% in the event of a repeat offense) if compliance is not achieved within the set deadline.
ISO 50001 Standard
Published in 2011 and revised in 2018, the international ISO 50001 standard is designed to support and assist companies committed to implementing a process aimed at reducing/controlling costs and improving their energy performance.
It is based on continuous improvement—a principle found in other standards, including ISO 45001 and ISO 14001—and is a source of energy savings for companies.
The standard pursues the following objectives:
- Helping companies use existing energy-consuming resources more wisely
- Promoting best practices in energy management and reinforcing positive behaviors in this area
- Helping operators evaluate and prioritize the implementation of new high-energy-efficiency technologies
- Providing a framework to promote energy efficiency throughout the supply chain
In practical terms, it requires an energy review, based on which companies define their energy objectives and targets.
This energy review forms the foundation of the entire process. It aims to:
- identify energy uses (lighting, steam production, heating, etc.),
- then determine significant energy uses based on analyses of energy consumption and usage,
- and prioritize potential energy performance improvements.
ISO 50001 certified companies are exempt from energy audits, provided that the scope covered by the certification is identical to the scope subject to the audit requirement.
What approach should you take?
The energy review required by the ISO 50001 standard provides a precise assessment of the energy landscape and identifies areas for improvement, which is why the legislator exempts companies seeking ISO 50001 certification from the mandatory energy audit.
Faced with this situation, some companies are questioning whether to implement the ISO 50001 standard with ISO support to avoid conducting this energy audit.
Furthermore, while not identical, the energy audit and the energy review have a similar purpose: to identify potential sources for optimizing a company's energy efficiency. Likewise, since the information to be collected (invoices, consumption records, metering, measurement campaigns, etc.) is partially the same, it is reasonable to think that the value of these two approaches for the company is comparable. However, the energy audit and the energy review differ and are fundamentally based on two different perspectives.
The audit helps meet a legal requirement and detect opportunities for improvement. It is not associated with a process for validating its relevance or content. The legislator has not provided for sanctions for failing to implement the associated action plan, and ultimately, it only imposes an obligation of means, not of results. Nevertheless, the energy audit as provided for in the Energy Code offers an interesting snapshot of the company's situation, raises awareness among various stakeholders (Management, Purchasing, General Services, R&D, Maintenance, etc.), and helps initiate improvement actions.
Conversely, the ISO 50001 standard and its energy review aim to position the company in a process of continuous improvement regarding its energy performance by inviting companies to place energy efficiency at the heart of their challenges and, therefore, their organization. To this end, the energy review is a periodic and iterative process with a precise methodology in which assumptions about future consumption must be defined. Additionally, the ISO 50001 standard requires a careful examination of results, which constitutes a minor revolution in the field of ISO standards. For this, companies are required to define energy performance indicators that must be periodically reviewed and compared against the baseline consumption.
In this context, committing to an ISO 50001 management approach implies a strong will and a desire to deploy a progress-oriented strategy at all levels of the company (facility design, equipment purchasing, etc.) with the goal of structuring the approach and exploring a wide range of improvements.
The standard requires more resources and greater management commitment than an energy diagnostic and mandates regular, sustained action. The choice is therefore not really a question: companies wishing to undertake an ISO 50001 approach solely to avoid the regulatory energy audit are certainly not well-advised to follow this path. Conversely, the ISO 50001 standard can be a formidable tool for durably embedding energy performance into the company's practices and strategy, thereby reducing not only costs but also its environmental footprint.