What are the common non-conformities raised on an ISO 14001 audit?
What stage of the certification process are you?
It depends on the stage of the certification process you are at. If you are at the beginning of your journey to certification
Stage 1 or Gap Analysis
The most common nonconformances are around documentation being missed – for example the criteria for determining significance (6.1.2 needs to be documented) scope of your management system (4.3 needs to be documented)
Stage 2 or Surveillance
Some of the most common nonconformances are as follows: -
1) Evaluation of Compliance (9.1.2) – even if you have identified all relevant compliance obligations (6.1.3) and you believe you are compliant with them can you demonstrate how you know you are complaint? 9.1.2 requires an organisation understands it’s compliance status – which is different to identifying it so tread carefully. My recommendation would be to add a column or 2 to your legal register – 1 that says compliance status and the other one that states how you know (for example: daily/weekly inspections of XXX)
2) Saying you do something, and for some reason you do it differently – ever put something in a procedure or other document and then changed the process for the better?
Time and time again organisations forget to update documentation when they put either something new in place or an improvement in place – 7.5.2 “Control of documented information” – make sure you review the documentation but also any new risks / opportunities because of the change and especially if the change has also created a new environmental impact
3) Consideration of environmental aspects for “abnormal” situations. Organisations are normally good at identifying their aspects and impacts for all their products, services, and activities (as required by 6.1.2) however if you read the requirements carefully you will see that there is a requirement to consider the aspects and associated impacts for normal, abnormal, and emergency situations.
What does this mean?
Normal activities – the things you do on a daily / regular basis – the normal working hours/activities of your business
Abnormal activities – things that you plan to happen but are outside of the normal activity of the business – for example maintenance of a machine (yes some of you will believe this to be a normal activity) – why do you need to consider these? Because the environmental impact may be different.
Think along the lines of running a printing machine – when this is operational there will be environmental impacts but when the machine is either being serviced or maintained the impacts might be different and therefore the existing controls may need to be changed
Emergency Situations/Potential Emergency situations – these are the things that you need to plan to respond to but not plan to happen. Things that could happen such as oil spill, flood, fire – these will certainly have a different environmental impact – therefore when you look at either an activity or a process you need to consider what could potentially go wrong and feed this into your emergency response plan (8.2)
Life cycle perspective
Another misconception is that the standard now requires you to do a full life cycle assessment – very difficult to do and get it accurate (if 1 thing changes then the assessment is no longer valid) – this however is NOT a requirement of ISO 14001:2015
It does however require an organisation to “Consider” aspects and impacts (6.1.2) and Operational control (8.1) from a life cycle perspective.
How does your organisation demonstrate that this has been considered? Again this could lead you to a nonconformance if you can’t demonstrate that you have made this consideration
Does your approval of suppliers and / or contractors include any specific environmental requirements? Do you ask your suppliers to use recycled packaging for example?
Even though the standard is currently NOT asking for a full assessment (cradle to grave) you do need to demonstrate that you are considering your impacts both downstream (suppliers) and up stream (sales) as well as (where applicable) you are considering the end of life of the product you make?
Your organisation designs and manufactures a product – can you put some environmental requirements on the suppliers of the raw material (life cycle) – can you design out some of the significant impacts of the product when in use (life cycle) – can you design and manufacture the product is either a biodegradable material or a recyclable material?
If the answer to any of the above is yes – can you take on board one or more of these options? If yes then set an objective to do it (6.2) if the answer is no – still document the information as you have met the requirements to “consider from a life cycle perspective” 6.1.2