Bridging Health and Sustainability: ISO 13485 Meets Climate Change

In early 2024, the International Organization for Standardization (ISO) issued a climate change amendment that quietly reshaped the expectations for how organizations approach environmental issues within their management systems. Though the language of the amendment is brief — just two new sentences — it represents a significant shift in how standards like ISO 13485 are interpreted and implemented.

Clause 4.1: Understanding the Organization and Its Context

The organization shall determine whether climate change is a relevant issue.

This line introduces a new requirement: organizations must proactively evaluate the relevance of climate change to their operations, rather than assuming it’s irrelevant or out of scope. For companies certified to ISO 13485, this means considering whether climate-related factors — such as extreme weather, resource scarcity, or carbon regulations — could influence their ability to maintain quality and compliance in medical device manufacturing or service delivery.

This change reframes climate change from being an optional sustainability add-on to a strategic business consideration. It invites organizations to think about climate risk alongside other external factors, like market dynamics or regulatory changes. For example, if a medical device company’s sterilization facility is located in a region prone to flooding, or if global supply chains are vulnerable to temperature-sensitive logistics, these are now part of the contextual analysis required under Clause 4.1.

Clause 4.2: Understanding the Needs and Expectations of Interested Parties

Relevant interested parties can have requirements related to climate change.

This addition broadens the scope of stakeholder analysis. Organizations are now expected to recognize that customers, regulators, investors, and even patients may have climate-related expectations that could affect the QMS. Hospitals and procurement bodies may request carbon footprint data. Regulatory authorities may begin incorporating environmental impact into product approval or post-market surveillance. Investors increasingly consider environmental, social, and governance (ESG) metrics when evaluating companies.

In short, the QMS can no longer be developed in a vacuum. Climate change is not just an environmental concern — it’s also a business driver, influencing stakeholder demands and shaping how organizations demonstrate accountability and transparency.

A Small Edit with Big Implications

Though these changes appear modest on the surface, they signal a major evolution in ISO’s philosophy: climate change is now seen as a strategic factor that affects quality, risk, and resilience — even in highly regulated, safety-critical sectors like medical devices. ISO is asking organizations to adopt a broader, more future-focused mindset.

For companies already certified to ISO 13485, this means taking a fresh look at their contextual analysis, stakeholder engagement, and risk management processes. While not every company will find climate change to be a material issue, ISO now requires that the consideration itself is documented and justified.

In a world where environmental conditions are rapidly shifting, this amendment helps ensure that quality systems are not only reactive and compliant — but also resilient and forward-thinking.

The medical device industry is synonymous with innovation, precision, and the unwavering commitment to patient safety. For decades, companies operating in this space have focused on meeting rigorous regulatory standards, ensuring product quality, and driving technological advancement. But the world is changing — and fast. As climate change accelerates and environmental challenges intensify, the industry is being asked to broaden its perspective. The new climate change amendment to ISO 13485 is a reflection of this shift, urging manufacturers to look beyond compliance and consider their role in promoting global resilience and environmental responsibility.

Here’s why this shift is important:

• 🌡️ Climate risks can disrupt supply chains, especially those dependent on global vendors or sensitive materials.
• 🌍 Regulatory bodies and healthcare providers are prioritizing sustainability in procurement decisions.
• 🔍 Stakeholders increasingly demand transparency in environmental performance, including carbon footprint and energy use.

🌡️ Supply Chain Vulnerabilities Are Increasing

Medical device production often relies on complex, global supply chains, involving specialized components, sterile environments, and just-in-time delivery systems. These supply chains are becoming increasingly vulnerable to climate-related disruptions: extreme weather events, wildfires, rising sea levels, and transportation delays caused by heatwaves or floods.

A single climate-related disruption — such as a hurricane damaging a critical supplier’s facility or an unexpected drought halting the availability of a necessary raw material — can have cascading effects on product availability, manufacturing timelines, and ultimately, patient care. Recognizing these risks within your QMS, as prompted by the ISO amendment, isn’t just good practice; it’s an essential step toward business continuity and operational resilience.

🌍 Sustainability Is Becoming a Procurement Priority

Governments, hospitals, and healthcare providers are increasingly embedding sustainability into procurement decisions. Green public procurement policies and hospital sustainability initiatives are gaining traction around the world, particularly in Europe and North America. Medical device companies that can demonstrate environmental stewardship — from low-emission operations to responsible sourcing — are better positioned to win contracts and maintain long-term partnerships.

With the new ISO language encouraging organizations to consider climate-related requirements of interested parties, environmental performance becomes a competitive differentiator, not just a regulatory afterthought. Companies that lead on sustainability will be favored in procurement processes where climate-conscious decision-making is the norm.

🔍 Stakeholder Expectations Are Evolving

Investors, consumers, regulators, and employees are all paying closer attention to a company’s environmental, social, and governance (ESG) performance. Medical device manufacturers are no exception. Today’s stakeholders expect transparency around emissions, energy use, waste management, and climate-related risks.

Incorporating climate change into your QMS helps align internal practices with these expectations. It allows your organization to track environmental performance, identify opportunities for improvement, and report data that matters to both regulators and the market. More importantly, it helps future-proof your organization against the growing tide of climate disclosure regulations.

✅ Building a Resilient, Forward-Thinking Organization

Adding climate considerations to your ISO 13485 QMS isn’t about checking a box or appeasing a trend. It’s about future-proofing your business in a world where environmental instability is becoming the norm. It’s about anticipating risks before they become crises, and responding to stakeholder demands with transparency and accountability.

Ultimately, it’s about bridging health and sustainability — because delivering safe, effective medical devices also means ensuring the systems that produce and deliver them can withstand the challenges of tomorrow.

With the climate change amendment now formally part of ISO 13485, medical device manufacturers need to take action — not just to stay compliant, but to build a more resilient, informed, and sustainable quality management system (QMS). While the changes to Clause 4.1 and 4.2 may seem minor in terms of wording, they require meaningful internal reflection, documentation, and potential process updates.

Here’s what organizations should focus on to respond effectively:

Revisit the Context of the Organization (Clause 4.1)

The first step is to update your analysis of the organization’s context. This means asking a critical question: Is climate change a relevant issue for us? The answer will vary depending on your location, products, suppliers, infrastructure, and customer expectations.

Even if your operations seem insulated from direct climate risks, indirect factors — such as energy costs, supply chain reliability, or investor concerns — may still make climate change relevant. If climate change is deemed not relevant, that judgment needs to be justified and documented.

If it is relevant, you should:

• Identify specific climate-related risks or opportunities (e.g., flooding risk at facilities, rising logistics costs).
• Integrate these into your existing risk-based thinking frameworks.
• Flag climate change as part of strategic discussions during management reviews.

Update Stakeholder Analysis (Clause 4.2)

Clause 4.2 now states that interested parties may have requirements related to climate change. Organizations must identify and review these evolving expectations. Stakeholders may include:

• Healthcare providers asking for greener packaging or low-carbon products.
• Regulators hinting at future climate disclosure obligations.
• Investors applying ESG (Environmental, Social, Governance) criteria.
• Employees pushing for sustainability commitments.

Map these climate-related expectations as part of your stakeholder analysis. For each group, ask: What climate-related expectations might they have? Are we meeting them?

This helps ensure your QMS reflects not just technical compliance, but also real-world accountability to those you serve and partner with.

Integrate Findings into Your QMS

Once you’ve assessed context and stakeholders, any relevant climate considerations should be embedded into your QMS processes, including:

• Risk management (Clause 6.1): Add climate-related risks to your risk register.
• Objectives and planning (Clause 6.2): Consider setting goals related to sustainability or climate resilience.
• Supplier management: Evaluate vendor exposure to climate risks or their own sustainability practices.
• Management review (Clause 9.3): Ensure climate relevance and stakeholder expectations are discussed at the top level.

Even if your findings are minimal today, this integration creates a framework for future updates as climate-related pressures evolve.

Train, Communicate, Document

Finally, ensure your team understands the new requirements. Conduct brief awareness sessions with quality and compliance teams. Update internal documents (like your Quality Manual or risk assessments) to reflect the climate consideration clause. This shows both auditors and stakeholders that you’re proactively responding to the amendment.