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morraphael  
#1 Posted : 08 September 2010 15:22:31(UTC)
Rank: Forum user
morraphael

I'm in the middle of an ISO14001 & OHSAS18001 certification audit. All going well other than the auditor has asked for a procedure to be written up to support 4.5.2 Evaluation of Compliance. Historically I've used the legislation register and a statement in the Company Management Arrangement Document stating the register is reviewed annually, whenever there is a change to legislation or whenever a new process is introduced into the workplace. In addition I outline where we obtain updates on OHSE legislation. Can anyone help in order to avoid a minor non-conformity. Cheers
boblewis  
#2 Posted : 08 September 2010 17:02:26(UTC)
Rank: Super forum user
boblewis

There have been many threads on this topic aand like most organisations you have fallen into the idea that this clause is about ensuring you have identified the relevant legislation and other requirements and kept them up to date. It is not - the identification is a separate clause. This clause is about how you ensure ongoing compliance with the regulatory and other requirements that you have identified as applicable to your work. An annual compliance audit is not sufficient. An ISO 14001 example might be the presence of a discharge consent for drains. Your Eof C would demonstrate how you ensured you complied with the consent, records of the compliance and an explanation of any infringements. This will not be a Minor Non Compliance if you do not resolve it quickly but even then you have not the records for certification in any case at this moment Bob
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