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Posted By Paul L Williams
Dear all,
At my last ISO 14001 audit I was given a scope for improvement (SFI) niote from the external auditor, which suggested that a environmental/legal checklist was used in the process of new development. I have asked the auditor for an example of a typical checklist other companies might use. However he has replied saying he doesn't have such a checklist and even if he did he would be unable to forward one due to their rules re: provision of consultancy services.
Can you help?, do you have an example checklist you could send me?
Thanks in advance for any help.
Paul
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Posted By Carrie Ellerby
Paul,
I'm a little confused - do you mean to have a list of legal requirements which may be applicable to new projects / equipment and you can check that this new project complies?
If so, then it will be very dependent on your business type, surely?
Carrie
PS: if you write what's written in the audit report (the wording of the improvement) it may make sense and I'll loook see if I can help :-)
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Posted By Paul L Williams
Carrie,
I was thinking more about the broad legal issues for checking environmental requirements for a new product rather than company/product specific ones. I wondered if anyone had a checkist that for example was like meeting the EHSR for a machine but for environmental issues?
By the way we are a paper coating company producing transfers, labels & stamps.
The statement the auditor put in the report was "The company was able to demonstrate that environmental considerations are made through the project implementation process. The company may wish to consider implementing a legal and other requirements checklist to help ensure a consistent approach".
Thanks
Paul
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Posted By Robert K Lewis
Paul
The auditor is attempting to point out to the company that they do have an ability to show that they take environmental matters into account when they are changing or modifying plant or process. The issue is that she/he feels that this could be better structured by a checklist of the legislation that applies in addition to the other requirements that also apply both voluntary and mandatory.
I am not familiar with your processes etc but in order to be certified you will have already identified these matters. You now need to structure the process steps that need to be done to make changes and then identify potential legal and other requirement impacts.
Remember the auditor is saying there is Scope for Improvement not that the system is deficient or missing a piece.
Bob
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Posted By Fred Pratley
As an ISO14001 holder, I am suprised at the auditors comment.
It implies that you do not have a list of the environmental legislation that might apply to your operations.
This was one of the first things we had to do to ensure we were legally compliant before BSI would confirm the ISO 14001 for us.
So how do you ensure that you are compliant and not breaching any regulation? Or are there so few that you don't need a list?
Regards Fred
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Posted By Robert K Lewis
Fred
I would think that the lack of the checksheet of legislation and other requirements is not what is referred to here as the category of note would have been either Improvement required or straight non-conformance.
We need also avoid the term "environmental Legislation" now as the new standard uses the term "legislation that has an environmental impact" which is much broader and could include COSHH etc.
Let us not forget also that the new clause 4.5 is much stronger in seeking evidence of compliance with legal and other requirements. This is one problem where I see many companies trying to rely on an annual audit to evidence compliance where what is needed is a much deeper ongoing system.
Bob
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Posted By David Muldoon
Paul
I 'think' the auditors coming from one of two points of view.
Firstly, 4.3.1 now states that Aspects need to specifically consider 'new or modified activities, products and services'. To me this reads that if you are plannng any new developments you will need to do an environmental evaluation of options to work out which is best ( a bit like an EIA). Part of this would no doubt be a check against relevant legislation which makes sense.
Secondly, he may be getting at the new clause 4.5.2.1 whereby you need to review/audit against legal compliance such as a stand alone audit.
Hope this helps
David
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Posted By Paul L Williams
Thanks to everyone who has replied. I am currently reviewing the EMS legal register ready for the new standard. Adding as said previously by Robert COSHH, EA Guidance and other relevant requirements that has an environmental impact.
I will then reference the product and development procedure to a condensed version "checklist", which will hopefully satisfy the auditor.
Cheers
Paul
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Posted By Fred Pratley
Paul,
Rather then having a seperate checklist, could you simply add a section to each item of legislation in the register under the header of "Current Status"?
Fred
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Posted By Robert K Lewis
Paul
You might be going off at a tangent - if you let me have an email address I can let you have a look at one based around construction design and estimating.
The process needs to broken down into key topics and the legislation will enhance the steps to be taken. It is a guide through what needs to be done and thought about in a succinct form. Not merely saying - you need to consider this list of legisalation.
Don't forget that the new clauses talk about ensuring compliance on an ONGOING basis. I have yet to see a system that does this effectively. I kjnow many will come back with annual compliance audits, weekly nspections but these may not be enough to ensure compliance at all times!
Bob
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