ISO 14001 | IMS International LLP Blog

Evaluation of Compliance as part of ISO 14001 and OHSAS 18001

ISO 14001, Legislation, OHSAS 18001 No Responses »

Oct 052010

Clause 4.5.2 within ISO 14001:2004 and OHSAS 18001:2007 is often a weakness within an organisations system and in most cases the process is not fully understood. The European Co-operation for Accreditation produced a guidance document (EA-07/4) on this subject which can be downloaded here (EA-7-04) but some of the detail is shown below.

While certification of an Environmental Management System against the requirements of ISO 14001:2004 or OHSAS 18001:2007 is not a guarantee of legal compliance, (neither is any other means of control, including government or other type of control and/or legal compliance inspections), it is a proven and efficient tool to achieve and maintain such legal compliance.

Accredited ISO 14001:2004 or OHSAS 18001:2007 certification should demonstrate that an independent third-party (Certification Body) has evaluated and confirmed that the organisation has a demonstrably effective EMS or H&S to ensure the fulfilment of its policy commitments including legal compliance.

Certification Body auditors are required to audit conformity of an EMS or H&S to the requirements of ISO 14001:2004 or OHSAS 18001:2007. They are not required to make a direct evaluation of legal compliance since this is the requirement for the organisation nor is the auditor required to conduct a compliance audit, which would be the role of the environmental regulator or an auditor/inspector contracted specifically for this purpose.

It is the organisation’s responsibility, and a function of the EMS or H&S, to ensure that the organisation periodically evaluates compliance with each and every applicable legal requirement & it is aware of its compliance status. An EMS or H&S certified as meeting the requirements of ISO 14001:2004 or OHSAS 18001:2007 is expected to be able to identify the organisation’s compliance status.

The IMS auditor should be able to determine whether the organisation has established the necessary procedures and evaluated their legal compliance in sufficient depth to demonstrate legal compliance.

An IMS Auditor will evaluate the effectiveness of the organisations evaluation through:

sampling the organisation’s determination of compliance with examples of specific legal compliance
looking for evidence of compliance such as reviewing the waste transfer documentation
reviewing the organisations evaluation process to ensure that the process has covered all legal requirements
verify the capability of the evaluation, this may be through the competencies of the personnel performing the evaluations

The responsibility for legal compliance stays with the organisation, therefore the evaluation process you perform is significant to the effectiveness of your EMS or H&S Systems.

The evaluation process is similar to an internal audit process but the organisation should pay specific attention to the legislative requirements and if they are being effectively met.

As an example; waste transfer notes are currently required to be retained for 2 years for non hazardous waste and 3 years for hazardous, you also need to ensure that the organisation taking the waste is licensed and take the waste to a licensed facility for that type of waste. To evaluate compliance to this an auditor could select a number of waste transfer notes for the different types of waste streams within the organisation, ensure that the records are available, the person taking/collecting the waste has a valid waste carriers license and there is a copy of the waste management license/environmental permit for the disposal site which is valid for the type of waste received. The evaluation notes/evidence should be able to clearly demonstrate that documents and records have been reviewed and are satisfactory for ensuring legal compliance.

There is not necessarily a right or wrong way of evaluating your legal compliance but the auditor should have confidence in the system that you have implemented.

Free Construction Waste Management Workshops

ISO 14001, Legislation, News No Responses »

Sep 052010

The following information is taken from the Netregs website: Remade South East are offering free workshops for anyone in the construction business who needs help to improve how they deal with waste on site. Below are the course dates as per the netregs website, click on the registration hyperlink to book onto a course:

Event name	Date	Location	Registration details
Croydon Business Advice Open Day	Wednesday 29 September 2010	Fairfield Halls	HMRC
Remade South East construction workshop: Managing waste resources on construction sites	Thursday 16 September	Seattle Hotel, Brighton	Remade South East
Remade South East construction workshop: Site waste management plans – understanding your legal requirements	Thursday 21 October	Bricks and Bread Sustainable Living Centre, Aldershot	Remade South East
Remade South East construction workshop: Choosing sustainable products for construction projects	Tuesday 30 November	Trinity College, Oxford	Remade South East
EcoShow Live Northern Ireland	Friday 8 – Sunday 10 October	Kings Hall, Belfast	EcoShow Live
Manchester Business Advice Open Day	Tuesday 9 November 2010	Man City Football Club	HMRC

ISO Certification Application and Audit Process

AS9100, ISO 14001, ISO 9001 1 Response »

Jun 122010

Not everyone is 100% clear on the certification process from initial application to the certificate being issued so we have developed this simple flowchart to detail this. It also highlights what the auditor will be looking at during each of the stages (stage 1 and stage 2).

The same process will be followed should a currently certified client wish to add another site or standard such as ISO 14001 when they already have ISO 9001 in place.

If you require any specific or further information please do not hesitate to contact us.

ISO Certification Audit Process and what the Auditor will review during the stage 1 and stage 2 audit

Changes to Scopes of Certification

AS9100, ISO 14001, ISO 9001 No Responses »

Jun 042010

The scope of certification is often overlooked by clients and it is very important that the scope reflects your activities. The scope of certification needs to be unambiguous and consistent with your activities.

The scope of certification and audit is shown on the audit plans which is submitted a few weeks prior to the audit taking place, clients need to review this scope and ensure that no changes are required. Unplanned scope changes cannot be amended during the audit and any changes need to be formally submitted to IMS prior to any activity.

A review is required of the requested changes to ensure that the current assigned auditor is competent to perform the audit against the amended scope, and that enough time has been allowed to complete the audit including the changes required.

If your current scope of certification is the “Refurbishment of Private Dwellings” and you now expand into “Demolition of Properties” then this area will need to be audited in order to bring it into your scope. This process needs to be planned into the forthcoming audit and consideration needs to be taken for the auditor competence, no auditor will be allowed to arrive on the day of the audit and change the scope.

There will not generally be an issue bringing new activities into your scope and in most cases additional audit time will not be required. However, auditors are not authorised to make that decision during the audit, therefore it is very important that you let the head office know prior to the audit that you wish to make a change to the scope.

Please ensure that when you receive the audit plans these are reviewed for content and times and the scope remains accurate. Contact the head office as soon as possible to request a scope change, this must be received in writing.

If you have any questions regarding the above then please do not hesitate to contact us.

Handling, Transfer and Transport of Waste

ISO 14001, Legislation No Responses »

Jun 022010

The government proposes to bring into force two new sets of regulations in England and Wales in 2010-2011 to deal with the handling, transfer and transport of waste.

The proposals will affect businesses that:

produce waste
import waste
carry or transport waste
keep or store waste
treat waste
dispose of waste
operate as waste brokers or dealers.

This means that the proposals will affect most businesses. In particular they will affect the waste management industry and farmers.

The details of these draft regulations are not yet available but they are likely to be:

1. Regulations to deal with waste carrier and broker registration.

These will:

simplify the existing waste carrier regulations and make them more effective
require waste brokers and dealers to register with the Environment Agency
set out requirements for transfer notes
increase the maximum level of fines and make more use of fixed penalty notices in enforcing the regulations

2. Regulations to control the stop, search and seizure of vehicles as part of the waste controls enforcement regime.

These will:

streamline the procedures for seizing and disposing of any vehicle used in an illegal waste operation
tighten up procedures for tracing the registered keeper of any vehicle used in an illegal waste operation.

This information is courtesy of Netregs

Control of Pollution (Oil Storage) Regs (NI) 2010

ISO 14001, Legislation, News No Responses »

Jun 012010

The Department of the Environment for Northern Ireland (DOE) is consulting on new regulations to introduce minimum requirements for new and existing above ground storage facilities.

The regulations will effect oil storage tanks over 200 Litres in size and is due for release in the Autumn of 2010. Draft Regs have been published and can be downloaded from the Netregs website.

All tanks will need to be bunded (secondary containment), the bund must have a capacity of not less than 110% of the containers storage capacity or, if there is more than one container within the system, of not less than 110% of the largest container’s storage capacity or 25% of their aggregate storage capacity. Those of you who are already ISO 14001 Certified and store waste chemicals will be used to this practice as part of your Hazardous Waste Controls.

Some of the other requirements will detail the positioning and protection requirements for tanks, the maintenance checks to be performed to prevent leaks and fixture and fitting requirements.

The consultation period is due to finish in June, IMS will publish information upon its formal release.

Integrating ISO 9001 and ISO 14001

ISO 14001, ISO 9001, Tools of the Trade 1 Response »

May 152010

More and more organisations are beginning to introduce ISO 14001:2004 (Environmental Management Systems) into their business and are never quite sure if they should integrate the requirements with their already existing ISO 9001:2008 Quality Management System. In our experience this is a suitable option for most organisations and is relatively easy to carry out.

Due to a number of the clauses being almost identical but essentially following the same process it makes sense to combine these procedures to streamline the system and make it more manageable for users.

For example, both standards require control of Non-conformance’s, Corrective Actions and Preventive Actions and although the standards are different the process for controlling these will be the same. You can have a non-conformance against a product or process requirement within ISO 9001 but then a non-conformance against an environmental incident such as a spillage in ISO 14001. Although the non-conformance is different, the process for identifying the root cause and introducing correction and corrective actions will be the same. In both cases you need to establish how the non-conformance occurred and how you are going to correct the root cause to ensure that the same issue does not reoccur.

The management review can follow the same process. Both standards require you to perform a management review, they may have different input and output requirements but there is no need to hold tow meetings as the process of going through the inputs and reviewing data will be the same. As long as your system captures the requirements of both standards auditors will be happy for you to combine the review process.

Internal Audits is another process that can be integrated fairly easily. Again, the process of performing the audits will be the same, you will just be looking at different specific areas at various points. You will however notice that the auditor will only need to audit some of the processes once; ensuring that the requirements of both standards are covered (training etc).

There are a number of consultants who are experienced with both standards and the process of integrating these. A list of possible consultants can be found on the IMS main website but others are available.

Difference Between Corrective and Preventive Actions

AS9100, ISO 14001, ISO 9001, Tools of the Trade 2 Responses »

May 132010

Introduction

There are two clauses within the ISO 9001 standard that appear to cause many people confusion as to their difference and how to approach each of them; 8.5.2-Corrective Actions & 8.5.3-Preventive Actions.

Within the standard the wording within each of the clauses is very similar which is probably where most of the confusion stems from.

8.5.2 Corrective Actions:

“The organization shall take action to eliminate the causes of nonconformities in order to prevent recurrence.”

8.5.3 Preventive Actions:

“The organization shall determine action to eliminate the causes of potential nonconformities in order to prevent their occurrence.”

Main Difference

You can clearly see from the excerpts taken from the ISO 9001 standard that Corrective Actions are taken as a result of non-conformances whilst Preventive Actions are taken against potential non-conformances to prevent them from ever occurring.

You should not be raising Preventive Actions after a non-conformance has occurred, you should only be raising Corrective Actions.

Corrective Actions

To address the Corrective Action clause you should be identifying the root cause of non-conformances that have already taken place and implementing immediate corrective actions to contain the situation and long term corrective actions to prevent their re-occurrence.

Detailed information on root cause analysis and techniques can be found within other guidance notes available on the IMS website.

Preventive Actions

This is usually where people take a step in the wrong direction, it is often seen that organisations are raising preventive actions as a result of a non-conformance and after they have identified corrective actions. Because they see the word “Preventive” within the clause they believe this means to prevent the non-conformance from re-occurring.

Types of Preventive Actions can include processes such as performing risk assessments against product, processes and health and safety activities. You are aiming to prevent a non-conformance from ever occurring by taking preventative measures.

Most organisations take Preventive Actions without knowing they are. Within the construction industry you will commonly see kick off and progress meetings throughout projects, these are preventive actions as the members present at the meeting will be discussing potential problems which may hold back the progress of the project.

Observations raising during internal audits could be classed as Preventive Actions as they can suggest improvements within the system to prevent non-conformances from occurring in the future.

Customer feedback is another method that can be used as Preventive Action evidence as customer suggestions may prevent any issues from being raised in future with regards to the service or product you provide.

Hopefully now the above information has helped clarify any missunderstandings over the difference between Corrective and Preventive Actions. you can download this guide by clicking here. If you need some further clarification please do not hesitate to contact one of our auditors.

Consent to Discharge

ISO 14001, Legislation, News No Responses »

May 092010

Many activities within your organisation may require a consent to discharge, these activities can include metal finishing processes such as Anodising, Powder Coating, De-greasing and Cleaning. Other industries can be effected such as Construction when performing groundwork activities and any vehicle washing processes including your own transportation.

If you are applying for ISO 14001:2004 certification through IMS you need to ensure that you have all of the correct permits and consents in place, if you are performing any activities that requires trade effluent to be discharged into the water system then an Environmental Permit or Exemption will be required before certification can be granted.

On the 6th April 2010 Environmental permits replaced discharge consents and groundwater authorisations and permits on. If you already had a consent, authorisation or permit before this date it will have become an Environmental Permit automatically.

England and Wales

You must have an environmental permit or a registered exemption from the Environment Agency if you carry out any water discharge activity or groundwater activity.

Water discharge activities include:

discharge of poisonous or polluting matter or waste matter, trade effluent or sewage effluent into inland freshwaters, coastal waters and estuaries
discharging trade effluent or sewage effluent from land by a pipe into the sea
removal of material from the bottom, bed or channel of inland freshwaters that has built up at a dam, weir or sluice, by causing any of that material to be carried away in the water
cutting or uprooting large amounts of vegetation in or nearby any inland freshwaters if you do not try to remove the vegetation from the water.

Groundwater activities include:

discharging a pollutant directly into groundwater
discharging a pollutant that might indirectly enter groundwater
any other discharge that might cause a pollutant to enter groundwater directly or indirectly.

Groundwater is all water below the surface of the ground, in the saturation zone, ie below the water table.

Northern Ireland

If you discharge anything other than clean, uncontaminated surface water you must have a:

discharge consent for discharges to surface water
groundwater authorisation for discharges to groundwater.

Scotland

If you discharge anything other than clean, uncontaminated surface water to surface water or groundwater you must have:

an authorisation under the Controlled Activity Regulations (CAR)
an integrated pollution control (IPC) authorisation or pollution prevention and control (PPC) permit.

For further information or to apply for an Environmental Permit or consent to discharge please visit www.netregs.gov.uk.

5 Whys Technique

AS9100, ISO 14001, ISO 9001, Tools of the Trade No Responses »

May 082010

Many organisations struggle to identify the underlying problem with regards to non-conformance’s and find that what they have introduced to address any issues often doesn’t solve the problem and the same issues reoccur.

There are numerous techniques that can applied to identifying the root cause of non-conformance’s, probably the simplest of these being the 5 whys technique. Within IMS International we use this technique ourselves when non-conformance’s have been identified and have found this problem solving tool to be very effective.

The system is straightforward to implement, and once you get the hang of the process you can generally work through most issues within a matter of minutes.

By asking the question “Why” you can separate the symptoms from the causes of a problem. This is critical as symptoms often mask the causes of problems.

How to Use the 5 Whys
1. Assemble a team of people knowledgeable about the area of non-conformance. Include
as many personnel as possible.
2. Have the team members ask “Why” the Problem as described could occur, and write the
answer down underneath the Problem description.
3. If the answer provided from 2 (above) does not solve the Problem, you must repeat the question “why” until you do.
4. If the answer provided from 2 (above) seems likely to solve the Problem, make sure the
team agrees and attempt a resolution using the answer. You may find that there are
more than one root causes to the problem.

Example

Non-conformance:
The CNC Machine keeps failing.
• Why 1
Why did the equipment fail? Because the circuit board burnt out.
• Why 2
Why did the circuit board burn out? Because it overheated.
• Why 3
Why did it overheat? Because it wasn’t getting enough air.
• Why 4
Why was it not getting enough air? Because the filter wasn’t changed.
• Why 5 and Root Cause
Why was the filter not changed? Because there was no preventive maintenance schedule in
place informing the operator to do so.

Using the above example, you can change the circuit board and you can change the filter but it would not necessarily prevent the same thing happening again. Those two items would form the basis of immediate correction action but not effective long term corrective action. To ensure effective long term corrective actions you would introduce a preventive maintenance programme for the machine, at this point you should also review preventive maintenance plans with other machinery within the organisation as you could have the same issue elsewhere.

Although the technique is called 5 whys, you may ask the question more than 5 times so do not stop just because you get to the 5th why, continue until you are satisfied that you have identified the true root cause.

As you can see from the example, the 5 whys technique is very simple to use and if performed correctly it can be very effective in identifying and addressing root causes for non-conformance’s.

If you have any questions regarding the technique then please speak to one of our auditors, all of which are trained in the use of the technique and will follow the process when reviewing submitted corrective action plans by clients.

For further information you can download the IMS guidance note on the 5 Whys Technique .

Newer Entries

Evaluation of Compliance as part of ISO 14001 and OHSAS 18001

Free Construction Waste Management Workshops

ISO Certification Application and Audit Process

Changes to Scopes of Certification

Handling, Transfer and Transport of Waste

Control of Pollution (Oil Storage) Regs (NI) 2010

Integrating ISO 9001 and ISO 14001

Difference Between Corrective and Preventive Actions

5 Whys Technique

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