Why ISO 14001 Standards Certification?

It’s always a good time to line up for a session with an ISO 14001 consultant. For most companies, this is really a good way of looking better. In reality though, certification can do so much more than polish company image. It is also the best way to make sure that a company has such strong values that its systems are structured in such a way as to limit negative environmental impact.
For a lot of businesses, general objectives revolve mainly around making more profits. These days though, it is hardly feasible or wise to maintain only this single-minded drive. Nearly every business, regardless of type or size can have an impact on the environment. Whatever you do can either worsen environmental degradation or help in preservation. It is now therefore, every business owner’s responsibility to strike a balance between making profits and promoting environmental responsibility.
This is where becoming ISO 14001 certified becomes important. To be exact, certification is a form of acknowledgement. Certified companies are recognized as holders and users of comprehensive environment management systems.
What the 14001 standards really seek to provide are generic standards. This can’t be helped. Specific points are difficult to come up with since businesses aren’t all the same. This isn’t exactly a negative aspect though. After all, there are many general terms and standards that are applicable and even necessary to companies that belong to different sectors.
Read more on ISO 14001 Standards at http://www.iso9001-standard.us

About ISO 14001:2004 Standards

The ISO 14001 aims to reduce the environmental carbon footprints that many businesses leave behind today because of not taking the right steps to be environmental sustainable. This standard promotes the decrease in the waste of necessary business resources and also reduces the pollution that can sometimes be a by product of a business.

About ISO 14001

The most updated version of the ISO 14001 was released in the year 2004 by the International Organisation of Standardization (ISO), which was attended by members from all the committees from around the world. In order for a company to be awarded the ISO 14001 standard certificate, an external auditor has to audit the company by an audit body that has been accredited by an accreditation body. The certification auditors are required to be accredited by the International Registrar of Certification Auditor and the certification body has to be accredited by the Registrar Accreditation Board in the USA or by the National Accreditation Board in Ireland.

The structure of ISO 14001 is very much like the ISO 9000, which is management standard, so these two standards can be implemented side by side to achieve the best results. As a part of the ISO 14000family, which deals with different aspects of environmental issues, ISO 14001:2004 and ISO 14002 deal with environmental management system (EMS). ISO 14001 gives the requirements for the

EMS and ISO 14002 gives the basic guidelines for EMS.

Environmental Management System with ISO 14001:2004

The EMS, as per the requirements of the ISO 14001, enables the company, may it be of any size, location and income to:

• It helps the company improve its environmental strategy and this positively affects their environmental performance.
• It helps in identifying and controlling the environmental impact that the activities, services or products of the company might have.
• And it helps in carrying out a systematic approach to set environmental targets and objectives, to achieve these and also to demonstrate that they have been achieved.

How does it work?

ISO 14001 does not specify or chalk out a definite level that each business has to reach. If the performance was determined, then it would have to be done for every specific business. But that is not how it works and has a very different approach, like:

• The ISO has various standards dealing with environmental issues. ISO 14001 deals with a framework provided for a strategic and holistic approach to the businesses environmental policy, actions and plans.
• It gives the general requirements for the EMS.
• This also states the reference to the communication requirements for the communication of the environmental management issues between the company, stakeholders, the public and the regulators.
• As these standards are not company specific, any and every business can undertake them as long as they are dedicated to the continued and improved environmental performance and they have a commitment to comply with the set norms.

Global Warming & ISO 14001 Standards

It is not difficult to become a believer in global warming. According to the U.S. National Climatic Data Center 2001 was the second warmest year on record and it was the 23rd consecutive year of above normal temperatures. Perhaps most troubling is the fact that the rate of temperature increase is accelerating. Add to this the data just released from insurer Munich Re stating that deaths from natural disasters were more than double in 2001 versus 2000 and insured losses were up more than 50%.UNEP estimates that the extra economic costs of disasters attributable to global warming are running at more than $300 billion annually.

Some 180 countries are proceeding toward an expected ratification of the Kyoto Protocol by the end of this year. Of the six gases it will control CO2 is by far the largest contributing nearly 90% of the global warming impact. The primary source of CO2 is the burning of fossil fuels. Therefore the focus on energy will continue to increase.

Throughout the world different methods are being used to encourage reduced energy use. Japan has enacted the Energy Conservation Law in 1999 mandating huge efficiency improvements by 2004 for nearly all air conditioning products. The U.S. has revised ASHRAE Standard 90.1 for buildings to raise the minimum COP level for centrifugal chillers from the current value of 5.2 to 6.1 effective in October 2001. DOE and Green Seal have revised their recommended efficiency levels to an even higher level of 6.27.

Some countries use laws. Others use codes and standards. An increasing number of countries are using environmental costing which increases the price of energy thereby increasing the financial attractiveness of high efficiency products. European countries have been using such “carbon taxes” for more than a decade. However a rapidly growing trend in developing countries is the reduction of subsidies to energy industries “so prices more accurately reflect environmental impacts” according to OECD’s Environmental Strategy for the First Decade of the 21st Century.

China has shown leadership by reducing subsidies to the coal industry from $24.5 billion in 1990 to $10 billion in 1996 resulting in 7% emissions reduction while seeing a solid economic growth of 36%! China is now moving aggressively into environmental costing with the just announced (1/13/2002) 5-year environmental plan that commits 700 billion yuan ($84 billion) to help protect the environment. The government will provide the fist 65 billion yuan to initiate the project but will apply the “polluter pays” principle for the rest. The “environmental protection authorities will collect funds from the pollution-producing companies”. The impact on the price of energy is not known at this time. However it is clear that the addition of environmental costing will increase energy prices. According to a European Research Commission Report of July 2001 “The cost of producing electricity from coal or oil would double if costs such as damage to the environment and health were taken into account”.

The global movement to high efficiency is accelerating just like the rate of temperature increase. But this is not all that is changing. This second environmental threat of global warming is making it clear that we need to give combined consideration to ozone depletion and global warming. But more important is the need to focus on the real issue which is the total environmental impact not address each individual environmental threat in isolation. This includes the concept of environmental risk exposure, which recognizes that there are other environmental threats that are less well understood today. However, there are “no regrets” decisions we can make today (such as minimum refrigerant charge, minimum atmospheric life refrigerants, etc.) to minimize these risks.

Combined consideration would place more emphasis on reducing the use of CFCs, which are still being produced in developing countries until 2010 in accordance with the Montreal Protocol. Little attention is being given the large contribution to global warming from CFCs. Actions which cause confusion and delay the phaseout of CFCs cause increased environmental damage rather than lessening the environmental impact.

The other rapidly changing factor in the HVAC industry is the shift to becoming a hermetic industry, where refrigerant is contained throughout the life of a chiller and recycled for further use when the chiller is replaced. This simple understanding that “if it doesn’t get into the environment it does no harm” is a powerful argument, which will lead to the continued use of the most efficient refrigerants in such closed hermetic applications as chillers. In just 15 years annual refrigerants emissions from chillers have been reduced from 25% to well below 1% today. This defines a whole different world than that which existed when the Montreal Protocol was crafted some 15 years ago.

But perhaps the most important change coming to our industry is the realization that there are no new or “perfect” refrigerants waiting to be discovered. There are eight elements that can be combined for use in a vapor compression cycle. All feasible combinations of these eight have been evaluated. The reality is “what we have now is all there is”.

This recognition is why we are now seeing a shift from the search for a perfect refrigerant to a search for the right refrigerant(s) for the right application. Said another way, the highest efficiency refrigerants for the lowest emissions applications. Many in our industry call this “Responsible Use”.

It is not difficult to become a believer in global warming. According to the U.S. National Climatic Data Center 2001 was the second warmest year on record and it was the 23rd consecutive year of above normal temperatures. Perhaps most troubling is the fact that the rate of temperature increase is accelerating. Add to this the data just released from insurer Munich Re stating that deaths from natural disasters were more than double in 2001 versus 2000 and insured losses were up more than 50%.UNEP estimates that the extra economic costs of disasters attributable to global warming are running at more than $300 billion annually.
Some 180 countries are proceeding toward an expected ratification of the Kyoto Protocol by the end of this year. Of the six gases it will control CO2 is by far the largest contributing nearly 90% of the global warming impact. The primary source of CO2 is the burning of fossil fuels. Therefore the focus on energy will continue to increase.
Throughout the world different methods are being used to encourage reduced energy use. Japan has enacted the Energy Conservation Law in 1999 mandating huge efficiency improvements by 2004 for nearly all air conditioning products. The U.S. has revised ASHRAE Standard 90.1 for buildings to raise the minimum COP level for centrifugal chillers from the current value of 5.2 to 6.1 effective in October 2001. DOE and Green Seal have revised their recommended efficiency levels to an even higher level of 6.27.
Some countries use laws. Others use codes and standards. An increasing number of countries are using environmental costing which increases the price of energy thereby increasing the financial attractiveness of high efficiency products. European countries have been using such “carbon taxes” for more than a decade. However a rapidly growing trend in developing countries is the reduction of subsidies to energy industries “so prices more accurately reflect environmental impacts” according to OECD’s Environmental Strategy for the First Decade of the 21st Century.
China has shown leadership by reducing subsidies to the coal industry from $24.5 billion in 1990 to $10 billion in 1996 resulting in 7% emissions reduction while seeing a solid economic growth of 36%! China is now moving aggressively into environmental costing with the just announced (1/13/2002) 5-year environmental plan that commits 700 billion yuan ($84 billion) to help protect the environment. The government will provide the fist 65 billion yuan to initiate the project but will apply the “polluter pays” principle for the rest. The “environmental protection authorities will collect funds from the pollution-producing companies”. The impact on the price of energy is not known at this time. However it is clear that the addition of environmental costing will increase energy prices. According to a European Research Commission Report of July 2001 “The cost of producing electricity from coal or oil would double if costs such as damage to the environment and health were taken into account”.
The global movement to high efficiency is accelerating just like the rate of temperature increase. But this is not all that is changing. This second environmental threat of global warming is making it clear that we need to give combined consideration to ozone depletion and global warming. But more important is the need to focus on the real issue which is the total environmental impact not address each individual environmental threat in isolation. This includes the concept of environmental risk exposure, which recognizes that there are other environmental threats that are less well understood today. However, there are “no regrets” decisions we can make today (such as minimum refrigerant charge, minimum atmospheric life refrigerants, etc.) to minimize these risks.
Combined consideration would place more emphasis on reducing the use of CFCs, which are still being produced in developing countries until 2010 in accordance with the Montreal Protocol. Little attention is being given the large contribution to global warming from CFCs. Actions which cause confusion and delay the phaseout of CFCs cause increased environmental damage rather than lessening the environmental impact.
The other rapidly changing factor in the HVAC industry is the shift to becoming a hermetic industry, where refrigerant is contained throughout the life of a chiller and recycled for further use when the chiller is replaced. This simple understanding that “if it doesn’t get into the environment it does no harm” is a powerful argument, which will lead to the continued use of the most efficient refrigerants in such closed hermetic applications as chillers. In just 15 years annual refrigerants emissions from chillers have been reduced from 25% to well below 1% today. This defines a whole different world than that which existed when the Montreal Protocol was crafted some 15 years ago.
But perhaps the most important change coming to our industry is the realization that there are no new or “perfect” refrigerants waiting to be discovered. There are eight elements that can be combined for use in a vapor compression cycle. All feasible combinations of these eight have been evaluated. The reality is “what we have now is all there is”.
This recognition is why we are now seeing a shift from the search for a perfect refrigerant to a search for the right refrigerant(s) for the right application. Said another way, the highest efficiency refrigerants for the lowest emissions applications. Many in our industry call this “Responsible Use”.

Demographers now project that, in the near future, more people are going to live in cities than in rural areas, and this will be the first time in the history of the world that this has been the case. As a result, while there are many different levels of society and business where global warming needs to be dealt with, cities are going to take an ever expanding role. It’s easy for local governments to pass the buck to state, provincial, or national governments, but this isn’t a sustainable practice. If we’re going to successfully fend off the apocalyptic-scale global warming that many scientists now predict, cities are going to have to take the lead. As a start, here are some basic things that municipal governments can do.

Green roofs: If you fly over any major metropolitan area, you’ll likely see a few patches of green where there are parks or tree-lined streets, but for the most part you will see nothing but bare rooftops dominating the landscape. When you think about it, that’s a lot of space that is simply going to waste. In the city of the future, we’re going to increasingly put all this excess space to use for green purposes. There are a few things we can do up there, including:

• Having solar and wind power stations on roof tops can help make buildings and cities in general cleaner and more energy efficient.

• Rooftop gardens can help residents grow their own produce rather than having to buy from energy-inefficient sources.

• Rooftop trees and greenhouses help balance out deforestation while cleansing smog-filled urban atmospheres.

Expanded public transit: When it comes to moving people around, the private automobile is the most energy-inefficient vehicle ever created. Things like buses and trains are not without emissions, but they have a much lower pollution-per-person ratio. Many cities throughout the developed world are decades behind in this respect and need to catch up fast in order to do their part. We need more rail-based transit systems, and many cities would do well to expand their bus networks.

Pedestrian and bicycle infrastructure: In many cities, it’s a sad state of affairs for pedestrians. If you want to travel on foot, you too often have to deal with landscapes that make walking very difficult, not to mention the culture of motorists who drive fast and aggressively and are not used to sharing the road. For a more sustainable future, we need more pedestrian-friendly landscapes, and it also doesn’t hurt to encourage people to take their bicycles.

Better recycling programs: We have come a long way in the realm of recycling, but too many cities are still stuck in the 90s with their recycling technology. We now have the ability to recycle a much broader spectrum of materials, including plastic bags and soiled containers, but many cities haven’t taken the steps necessary to implement these technologies. This investment, which is relatively small in the big picture, can have hugely positive effects in the long run.

Fuel-efficient fleets: Most cities rely on large fleets of vehicles to provide their basic services. From buses, to sanitary trucks, to road maintenance equipment, all of these vehicles can be made more efficient with new technology. Of course, it costs a lot of money to replace these vehicles, but all vehicles do need to be replaced with newer models sooner or later, and cities should use these opportunities to make their investments more efficient, rather than purchasing the same old polluting vehicles.

As individuals, each of us can contribute to the solution. As a start, we can choose to drive vehicles that are more fuel-efficient. We can plant more trees. We can recycle where practicable. We can take stock of our energy consumption practices and try to reduce them by some factor.

But, what steps can your organization take to help? The answers are varied, depending upon the size of the organization and the related environmental aspects and impacts. But no matter how simple or complex the business, each can benefit from the implementation of a management system based onISO 14001:2004. This international standard has as its focus the prevention of pollution, accomplished by a teamwork approach to identifying those aspects of the organization’s processes that have the potential for harming the environment and the development of ways to reduce or prevent this harm. In the process, many organizations have found ways to reduce costs by elimination of scrap, changes to their waste disposal processes or reduced use of natural resources. It is the application of the system approach that has proven to be successful. And, once the system is in place, it is logical and beneficial to have that system certified and registered. This provides added assurance that the management system remains effective and also provides public recognition to numerous stakeholders that your organization is committed to the prevention of pollution.

Go to http://www.iso9001store.com for more information on ISO 14001 Standards.

The Difference Between Compliance Auditing and Systems Auditing In ISO 14001

Often however, there is confusion between regulatory compliance auditing and EMS auditing. This is because there are many elements of regulatory compliance that overlap with the EMS. Recall that the criteria in a compliance audit are the applicable regulations, whereas the criteria in an EMS audit would be ISO 14001. But does not ISO 14001 address compliance? The answer is yes, but from a system standpoint, not performance.

In other words, the standard requires that certain procedures exist regarding identification of legal and other requirements, that periodic compliance assessments be performed, that legal requirements be considered in setting objectives and targets, and that there be a commitment to compliance. However, actually being in compliance is a performance issue, and out of the purview of ISO 14001.

Of course, a system that is constantly out of compliance or does not identify and initiate action to correct noncompliances, will eventually fail due to system failure. The subtle, yet important point is that during an EMS audit, identified regulatory noncompliances are relevant only to the extent that they reflect a potential system problem. The finding therefore is not that the site is out of compliance with a given regulation, but that the noncompliance means some EMS element is not conformed to. For example, a regulatory noncompliance can be related to a problem with training, recordkeeping, or monitoring and measurement.

The EMS auditor is not to do a compliance audit as part of the EMS audit. If, as part of the statistical sampling to verify EMS element requirements, the auditor identifies a regulatory noncompliance, he or she treats it as any other evidence.

This point has been difficult to accept, especially in U.S. industry because of our long history of regulatory enforcement. The EMS auditor needs to constantly remember that compliance auditing is being done separately as part of the EMS requirements itself (4.5.1, paragraph 3) and to stay focused on the criteria at hand – ISO 14001 and the site’s EMS. There may be legal requirements regarding noncompliances encountered during the EMS audit, but this should be decided and addressed in the audit plan.

In summary, the goal of the compliance audit is to verify compliance with regulations, whereas the EMS audit’s goal is to verify that the EMS conforms to planned arrangements, including ISO 14001.

The Audit Plan In ISO 14001

The audit plan is the document that establishes the scope, objectives and criteria, and schedule of the audit. It also goes into specific details on what areas will be audited, when, and by whom.

Other details such as which checklists may be used, how the report is to be formatted and distributed, and how meetings will be conducted can also be included in the plan. In essence, the audit plan reflects the programs, procedures, and methodologies of the EMS audit process, in accordance with element 4.5.4 of ISO 14001. These planning items are usually described in the procedures for element 4.5.4 and do not need to be re-created every time an audit occurs. For example, it can be determined that the entire EMS will be audited once per year, but in four partial events. This schedule then becomes part of the procedure.

The audit scope defines what part of the organization will be audited. Obviously, this should coincide with the scope of the EMS itself, and is usually the site in question. If the full EMS audit is divided in smaller segments conducted throughout the year, then the scope of any given segment is what portion of the organization will be audited at that time. Typically, an organization will create a chart or matrix showing the various divisions of the site or activity and when it will be audited. A typical entry may show the maintenance department being audited in the first quarter and production in the fourth quarter, for example.

Also noted in the audit plan is the audit objective(s). The audit objective describes why an audit is being conducted. Typically the reason is to conform to ISO 14001 4.5.4 requiring that the EMS be periodically evaluated. Another reason is demonstrate conformance to others.

Although EMS audits may appear in their own right to be “good practice”, it is essential that auditors have a clear concept of what the general objectives of such audits are.

The definition of EMS audits highlights the need to confirm conformance with planned arrangements and to ensure that these arrangements are effective and suitable to achieve objectives. ISO 14011 expands this to form a number of general objectives for any type of EMS audit. Audits should be carried out to:

- determine conformance of an auditee’s EMS with the EMS audit criteria

- determine whether the auditee’s EMS has been properly implemented and maintained

- to identify areas of potential improvement in the auditee’s EMS

- assess the ability of the internal management review process to ensure the continuing suitability and effectiveness of the EMS

- evaluate the EMS of an organization where there is a desire to establish a contractual relationship, such as with a potential supplier or a joint-venture partner.

Using this definition and sources such as ISO 14010 and 14011, the following statement of the specific objectives of an internal EMS audit has been developed. Internal audits should be carried out to ensure that:

- The EMS continues to meet the needs of the business

- The necessary documented procedures that exist are practical and satisfy any specified requirements

- The necessary documented procedures are understood and followed by appropriately trained personnel

- Areas of conformity and nonconformity with respect to implementation of the EMS system are identified and corrective action implemented

- The effectiveness of the system in meeting the EMS objectives is determined and that a basis is created for identifying opportunities and initiating actions to improve the EMS system

The above objectives imply that internal audits are concerned with more than just the policing of an established system. If auditors and managers are to remain committed to the implementation of the EMS system, it must also contribute to the process of developing that system and seeking improvements.

Internal auditing must not be carried out in a way that results in the transfer of responsibility from the operating staff to the auditor or auditing organization, i.e., at all times the individual or department must retain and accept responsibility for his or her role in the EMS.

If the internal audit process is not designed and implemented to meet the objectives and to avoid the pitfalls described above, it is unlikely that the top management commitment essential to an effective audit process will be readily forthcoming.

The audit criteria define what the “rules” are. For the sake of this guide, the criteria will be the elements of ISO 14001. A subtle point to note however is that the site’s EMS requirements are also part of the criteria. This means that in addition to responding to the requirements of ISO 14001, the EMS must also respond to “planned arrangements”, or what the organization said it was going to do. In audits, a common response is “the standard does not require such and such detail”. However, if the site’s procedure does require some specific response, then it becomes part of the criteria. In essence, the auditors are verifying the system not only to ISO 14001, but also to what the EMS documentation states.

How the audit is divided and scheduled throughout the time interval is up to the organization and will be a function of minimizing disruption to site operations and resource needs. The only requirement is that the full audit be completed within the frequency established in the procedures under 14001, 4.5.4. One of the requirements regarding frequency is that how often an area is audited be in part a function of prior audit results. This means that the planned frequency may change with time based on what auditors are finding.

How long each audit takes again is a function of resource needs and operations. It is recommended, however, that any individual audit event not be protracted out over long time periods. The longer a task takes, the easier it is to get distracted and lose focus.

Much has been written about how to audit a system if the full audit is not completed in one event. Unlike other audits, including quality audits, where a more segmented approach can be taken, ISO 14001 systems tend to be very sensitive to consistency. For example, the emergency planning process may conform to the standard element 4.4.7 in that a procedure exists; however,

it may not reflect the potential significant impacts identified in element 4.3.1. Had the audit team focused only on element 4.4.7, they would not have noted the apparent nonconformance.

When developing an audit plan, it is wise to consider the three C’s of ISO 14001 EMS auditing:

Conformance, Consistency, and Continual Improvement. Conformance relates to addressing each of the requirements of the standard, i.e., the “shalls”. Consistency relates to how well each procedure or process of the EMS relates to the others. In other words, do objectives and targets reflect the policy commitments? Are personnel trained on the correct legal and other requirements? Finally, Continual Improvement requires that the system lead to improvements in the system itself as well as with environmental performance. A system that has all the prerequisite procedures, but remains static, is not in conformance.

The concepts of consistency and continual improvement are more subtle because they are through-running threads of the standard and not always a definitive statement. The required commitment to continual improvement and the text of the standard itself however do go some way towards reminding the auditor.

With the three C’s in mind, one now sees why it is best to audit all applicable elements of the standard in a given area at one time, rather that tracing any one standard element throughout various areas. For example, during the first quarter audit event, Company X may audit all of ISO 14001 in maintenance. During the second quarter event, all of ISO 14001 will be audited in the production area, and so on. This is in contrast to auditing only a certain element, i.e., corrective action, across several site areas in one audit event.

Now we know what is being audited, when it is being audited, and to what “rules” it is being audited. The remainder of the plan is simply then the logistics of the audit. The logistics include identification of team members, noting if and what checklists will be used, schedule and formats of meeting to name a few. Below is the full list of recommended audit plan elements as described in ISO 14011:

• the audit objectives and scope;

• the audit criteria;

• identification of the auditee’s organizational and functional units to be audited;

• identification of the functions and/or individuals within the auditee’s organization having significant direct responsibilities regarding the auditee’s EMS;

• identification of those elements of the auditee’s EMS that are of high audit priority;

• the procedures for auditing the auditee’s EMS elements as appropriate for the auditee’s organization;

• the working and reporting languages of the audit;

• identification of reference documents;

• the expected time and duration for major audit activities;

• the dates and places where the audit is to be conducted;

• identification of audit team members;

• the schedule of meetings to be held with the auditee’s management;

• confidentiality requirements;

• report content and format, expected date of issue and distribution of the audit report;

• document retention requirements.

If the internal audit is to proceed smoothly, it is helpful for the internal auditor to establish a dialogue prior to the actual audit with the person responsible for the area being audited. This dialogue may be conducted by memo, telephone, or during a formal or informal meeting. The main factor that should influence the auditor’s choice of method for setting up this dialogue should be the organization’s normal style or culture. Irrespective of the method of communication the auditor adopts, the following points should be established:

• The overall duration of the proposed audit

• The starting location and time

• The proposed scope and areas to be covered by the audit

• A timetable for approximate progress of the audit where applicable, e.g., if a number of different departments or geographical areas are to be included in the scope of the audit

• The arrangements for any close out meeting where the findings of the audit can be agreed and corrective action requirements discussed

• The personnel liable to be involved at each stage of the audit

If an auditor does not give sufficient attention to ensuring that clear agreement is reached with respect to the above points, the potential for misunderstandings that can affect the conduct of the audit is greatly increased. However, these initial communications with the personnel of the area being audited not only affect the “tone” of the forthcoming audit, but they can significantly influence the commitment and level of cooperation shown by that area throughout the audit process and for many subsequent audits.

Prior to commencing the audit, but once the plan is prepared, the audit team assignments are made, and working documents are defined. Working documents are those documents such as observation logs and checklists that are used during the audit to collect evidence, but are not necessarily retained as records. In other words, they may be discarded after the audit is complete and the report prepared.

Of these, only the checklist should require an input at this stage from the auditor. However, before compiling a checklist, the auditor must determine if the function and format of the checklist are prescribed by the audit procedure or whether personal preference can be exercised.

The format of the checklist may vary considerably, depending on whether it is intended to act as an aide or as a part of audit records showing the scope and conduct of the audit. The former may consist only of general topics to be covered during the audit, whereas the latter may be an extensive and detailed questionnaire on which details of sampling and answers to the questions are to be recorded.

The need for checklists and the type appropriate will vary according to other experience of the auditors and the culture of the company. It is recommended that for purposes of internal audits, checklists, even if limited, should always be developed. However, standard questionnaire type checklists not prepared by the auditor that must be slavishly followed and completed, should be

avoided. This latter type is likely to result in an unnecessary restriction in the scope of the audit and a stifling of auditor initiative.

Although an auditor should always work within the scope defined for the audit, the working documents must not be designed so that they restrict additional audit activities or investigations that may become necessary as a result of information gained during the audit. There are differences of opinion over whether it is preferable to create the checklist anew or whether a previously developed checklist can be used. Although the former is desirable in principle, it is not always practical in terms of the best use of the resources available. The best compromise is to utilize whatever available checklists are already in existence, but to review these critically

against the relevant documents previously identified. In this way, time can be saved in using them as a foundation without detracting from effectiveness.

The Audit Report In ISO 14001

Once agreement has been reached, both among the audit team and with the auditee, it is time to prepare the audit report. Note that ISO 14001 does not require a documented audit report. However, it is very difficult to verify that the auditing requirement has been satisfied without a supporting record, which is typically a documented audit report.

The audit report is prepared by the lead auditor, although he or she may have other team members prepare portions. The content of the audit report is determined by the audit plan and the organization’s EMS audit procedures. Having completed the examination phase and evaluated the collected data observations, etc., the assessor is faced with the problem of documenting any deficiencies he or she may have found. There are many different methods of documenting deficiencies, ranging from inclusion in the body of the audit report to producing non-conformance notes or corrective action requests. Irrespective of which method is adopted, the basic principles to be followed are similar. ISO 14001 does not dictate what should be in the report, and ISO 14011 only suggests contents. ISO 14011 indicates that at a minimum, the findings need to be in the report. The findings appear as a statement that the EMS is or is not in conformance with the criteria, and states what the criteria and supporting evidence are for the statement. ISO 14011 also lists other optional items to include such as:

• the identification of the organization audited and of the client;

• the agreed objectives, scope and plan of the audit;

• the agreed criteria, including a list of reference documents against which the audit was conducted;

• the period covered by the audit and the date(s) the audit was conducted;

• the identification of the auditee’s representatives participating in the audit;

• the identification of the audit team members;

• a statement of the confidential nature of the contents;

• the distribution list for the audit report;

• a summary of the audit process including any obstacles encountered;

• audit conclusions such as:

- EMS conformance to the EMS audit criteria;

- whether the system is properly implemented and maintained;

- whether the internal management review process is able to ensure the continuing suitability and effectiveness of the EMS.

The format of such reports can vary considerably and may range from completion of a simple pro-forma to expansive documents describing all aspects of the audit performance and findings. However, irrespective of the style and format, the audit report should cover the key topics already identified as being essential for discussion and presentation at the opening and closing meetings. In constructing the report two specific objectives must be borne in mind.

(1) The report has to provide objective evidence of effective implementation of the audit procedure.

(2) The report has to allow for corrective action to be addressed and that the follow-up requirements can be established and initiated.

Where there are non-conformances, there are various options regarding deficiency reporting. One option is to describe each of the deficiencies identified in the main body of the report along with any supporting evidence, and if requested, corresponding recommendations. Although this may result in a comprehensive report of audit findings, it has the disadvantage that the individual

deficiencies are often difficult to locate, particularly when trying to monitor follow-up actions.

This can be partly overcome by writing separate corrective action requests for this purpose. A useful alternative that is less time consuming is to restrict the description of deficiencies in the body of the report to general summaries only. Details of deficiencies can then be included in non-conformance notes. Ideally, the non-conformance note should also provide space for agreeing corrective actions and recording subsequent monitoring of that corrective action. In this manner, any duplication of effort with respect to audit reporting is minimized, thus producing a more easily managed system. It is important that however non-conformances are handled, it be constant with the EMS correction action process (ISO 14001, Section 4.5.2).

Before considering the steps in preparing the non-conformance note we must be clear about their purpose.

• To convey to the auditee the findings in a clear and accurate manner so that they know what to do next.

• To advise the EMS personnel or other auditors what you have found so that he can follow it up.

• To present a record that can be reviewed remotely from the scene and be understood.

All non-conformance notes must contain certain basic information.

• The physical area being audited.

- Failure to record this often results in great confusion 3 to 6 months later when a follow up visit is carried out to review corrective action implementation.

• The specific clause(s) of the assessment standard(s) against which the non-conformance is issued.

- If the auditor is unable to readily identify the applicable section of the EMS manual or the procedure against which to issue the non-conformance, he must question whether or not he is justified in writing the non-conformance. It is good practice to re-read the

requirements of the relevant system documentation to confirm that these can be interpreted as supporting the non-conformance. If they do not, then the non-conformance cannot be issued.

• The detailed nature of the non-conformance including the specific identity of documents/procedures/material, etc.

Earlier we considered the requirements for recording observations during the assessment and emphasized the need for them to be factual and to contain objective evidence that the system requirements were not being satisfied. Although this appears to be fairly straightforward, in practice this is often not the case. It is not unusual for inexperienced auditors to identify a deficiency only to fail to communicate the findings in a manner that facilitates implementation of the appropriate corrective action. The non-conformance note, while not being over long, must contain sufficient information to enable a person not present during the audit to be able to gauge the seriousness or otherwise of the observation.

The use of descriptive terms such as extensive, several, isolated, etc… is essential to communicate accurately the nature and extent of the deficiency, but care must be taken to ensure that their use does not result in a lack of objectivity; e.g., the term extensive can only be included if there is irrefutable evidence to justify its use. The auditor must also take care to ensure that the description is not only accurate but it is also fair, e.g., a statement that 50% of manifests were incorrectly signed may be accurate but is hardly fair if only two manifests were sampled.

Having documented the nature of the deficiency, some audit systems require the auditor to grade the deficiency or non-conformance, e.g., major and minor. It is not intended to discuss grading systems in detail since there are many potential variations that companies may wish to adopt. Irrespective of what system is being adopted, the auditor must ensure that the grading given and

the text describing the deficiency are completely compatible.

Distribution of the audit report and nature of documentation are decided between the auditor and auditee, although this too is usually addressed in the audit plan. An audit is considered successful when the auditee and client feel that they have useful, constructive feedback that allows them to improve the system.

The Difference Between Compliance Auditing and Systems Auditing In ISO 14001

The Difference Between Compliance Auditing and Systems Auditing In ISO 14001

Often however, there is confusion between regulatory compliance auditing and EMS auditing. This is because there are many elements of regulatory compliance that overlap with the EMS. Recall that the criteria in a compliance audit are the applicable regulations, whereas the criteria in an EMS audit would be ISO 14001. But does not ISO 14001 address compliance? The answer is yes, but from a system standpoint, not performance.

In other words, the standard requires that certain procedures exist regarding identification of legal and other requirements, that periodic compliance assessments be performed, that legal requirements be considered in setting objectives and targets, and that there be a commitment to compliance. However, actually being in compliance is a performance issue, and out of the purview of ISO 14001.

Of course, a system that is constantly out of compliance or does not identify and initiate action to correct noncompliances, will eventually fail due to system failure. The subtle, yet important point is that during an EMS audit, identified regulatory noncompliances are relevant only to the extent that they reflect a potential system problem. The finding therefore is not that the site is out of compliance with a given regulation, but that the noncompliance means some EMS element is not conformed to. For example, a regulatory noncompliance can be related to a problem with training, recordkeeping, or monitoring and measurement.

The EMS auditor is not to do a compliance audit as part of the EMS audit. If, as part of the statistical sampling to verify EMS element requirements, the auditor identifies a regulatory noncompliance, he or she treats it as any other evidence.

This point has been difficult to accept, especially in U.S. industry because of our long history of regulatory enforcement. The EMS auditor needs to constantly remember that compliance auditing is being done separately as part of the EMS requirements itself (4.5.1, paragraph 3) and to stay focused on the criteria at hand – ISO 14001 and the site’s EMS. There may be legal requirements regarding noncompliances encountered during the EMS audit, but this should be decided and addressed in the audit plan.

In summary, the goal of the compliance audit is to verify compliance with regulations, whereas the EMS audit’s goal is to verify that the EMS conforms to planned arrangements, including ISO 14001.

The Audit Plan In ISO 14001

The Audit Plan In ISO 14001

The audit plan is the document that establishes the scope, objectives and criteria, and schedule of the audit. It also goes into specific details on what areas will be audited, when, and by whom.

Other details such as which checklists may be used, how the report is to be formatted and distributed, and how meetings will be conducted can also be included in the plan. In essence, the audit plan reflects the programs, procedures, and methodologies of the EMS audit process, in accordance with element 4.5.4 of ISO 14001. These planning items are usually described in the procedures for element 4.5.4 and do not need to be re-created every time an audit occurs. For example, it can be determined that the entire EMS will be audited once per year, but in four partial events. This schedule then becomes part of the procedure.

The audit scope defines what part of the organization will be audited. Obviously, this should coincide with the scope of the EMS itself, and is usually the site in question. If the full EMS audit is divided in smaller segments conducted throughout the year, then the scope of any given segment is what portion of the organization will be audited at that time. Typically, an organization will create a chart or matrix showing the various divisions of the site or activity and when it will be audited. A typical entry may show the maintenance department being audited in the first quarter and production in the fourth quarter, for example.

Also noted in the audit plan is the audit objective(s). The audit objective describes why an audit is being conducted. Typically the reason is to conform to ISO 14001 4.5.4 requiring that the EMS be periodically evaluated. Another reason is demonstrate conformance to others.

Although EMS audits may appear in their own right to be “good practice”, it is essential that auditors have a clear concept of what the general objectives of such audits are.

The definition of EMS audits highlights the need to confirm conformance with planned arrangements and to ensure that these arrangements are effective and suitable to achieve objectives. ISO 14011 expands this to form a number of general objectives for any type of EMS audit. Audits should be carried out to:

- determine conformance of an auditee’s EMS with the EMS audit criteria

- determine whether the auditee’s EMS has been properly implemented and maintained

- to identify areas of potential improvement in the auditee’s EMS

- assess the ability of the internal management review process to ensure the continuing suitability and effectiveness of the EMS

- evaluate the EMS of an organization where there is a desire to establish a contractual relationship, such as with a potential supplier or a joint-venture partner.

Using this definition and sources such as ISO 14010 and 14011, the following statement of the specific objectives of an internal EMS audit has been developed. Internal audits should be carried out to ensure that:

- The EMS continues to meet the needs of the business

- The necessary documented procedures that exist are practical and satisfy any specified requirements

- The necessary documented procedures are understood and followed by appropriately trained personnel

- Areas of conformity and nonconformity with respect to implementation of the EMS system are identified and corrective action implemented

- The effectiveness of the system in meeting the EMS objectives is determined and that a basis is created for identifying opportunities and initiating actions to improve the EMS system

The above objectives imply that internal audits are concerned with more than just the policing of an established system. If auditors and managers are to remain committed to the implementation of the EMS system, it must also contribute to the process of developing that system and seeking improvements.

Internal auditing must not be carried out in a way that results in the transfer of responsibility from the operating staff to the auditor or auditing organization, i.e., at all times the individual or department must retain and accept responsibility for his or her role in the EMS.

If the internal audit process is not designed and implemented to meet the objectives and to avoid the pitfalls described above, it is unlikely that the top management commitment essential to an effective audit process will be readily forthcoming.

The audit criteria define what the “rules” are. For the sake of this guide, the criteria will be the elements of ISO 14001. A subtle point to note however is that the site’s EMS requirements are also part of the criteria. This means that in addition to responding to the requirements of ISO 14001, the EMS must also respond to “planned arrangements”, or what the organization said it was going to do. In audits, a common response is “the standard does not require such and such detail”. However, if the site’s procedure does require some specific response, then it becomes part of the criteria. In essence, the auditors are verifying the system not only to ISO 14001, but also to what the EMS documentation states.

How the audit is divided and scheduled throughout the time interval is up to the organization and will be a function of minimizing disruption to site operations and resource needs. The only requirement is that the full audit be completed within the frequency established in the procedures under 14001, 4.5.4. One of the requirements regarding frequency is that how often an area is audited be in part a function of prior audit results. This means that the planned frequency may change with time based on what auditors are finding.

How long each audit takes again is a function of resource needs and operations. It is recommended, however, that any individual audit event not be protracted out over long time periods. The longer a task takes, the easier it is to get distracted and lose focus.

Much has been written about how to audit a system if the full audit is not completed in one event. Unlike other audits, including quality audits, where a more segmented approach can be taken, ISO 14001 systems tend to be very sensitive to consistency. For example, the emergency planning process may conform to the standard element 4.4.7 in that a procedure exists; however,

it may not reflect the potential significant impacts identified in element 4.3.1. Had the audit team focused only on element 4.4.7, they would not have noted the apparent nonconformance.

When developing an audit plan, it is wise to consider the three C’s of ISO 14001 EMS auditing:

Conformance, Consistency, and Continual Improvement. Conformance relates to addressing each of the requirements of the standard, i.e., the “shalls”. Consistency relates to how well each procedure or process of the EMS relates to the others. In other words, do objectives and targets reflect the policy commitments? Are personnel trained on the correct legal and other requirements? Finally, Continual Improvement requires that the system lead to improvements in the system itself as well as with environmental performance. A system that has all the prerequisite procedures, but remains static, is not in conformance.

The concepts of consistency and continual improvement are more subtle because they are through-running threads of the standard and not always a definitive statement. The required commitment to continual improvement and the text of the standard itself however do go some way towards reminding the auditor.

With the three C’s in mind, one now sees why it is best to audit all applicable elements of the standard in a given area at one time, rather that tracing any one standard element throughout various areas. For example, during the first quarter audit event, Company X may audit all of ISO 14001 in maintenance. During the second quarter event, all of ISO 14001 will be audited in the production area, and so on. This is in contrast to auditing only a certain element, i.e., corrective action, across several site areas in one audit event.

Now we know what is being audited, when it is being audited, and to what “rules” it is being audited. The remainder of the plan is simply then the logistics of the audit. The logistics include identification of team members, noting if and what checklists will be used, schedule and formats of meeting to name a few. Below is the full list of recommended audit plan elements as described in ISO 14011:

• the audit objectives and scope;

• the audit criteria;

• identification of the auditee’s organizational and functional units to be audited;

• identification of the functions and/or individuals within the auditee’s organization having significant direct responsibilities regarding the auditee’s EMS;

• identification of those elements of the auditee’s EMS that are of high audit priority;

• the procedures for auditing the auditee’s EMS elements as appropriate for the auditee’s organization;

• the working and reporting languages of the audit;

• identification of reference documents;

• the expected time and duration for major audit activities;

• the dates and places where the audit is to be conducted;

• identification of audit team members;

• the schedule of meetings to be held with the auditee’s management;

• confidentiality requirements;

• report content and format, expected date of issue and distribution of the audit report;

• document retention requirements.

If the internal audit is to proceed smoothly, it is helpful for the internal auditor to establish a dialogue prior to the actual audit with the person responsible for the area being audited. This dialogue may be conducted by memo, telephone, or during a formal or informal meeting. The main factor that should influence the auditor’s choice of method for setting up this dialogue should be the organization’s normal style or culture. Irrespective of the method of communication the auditor adopts, the following points should be established:

• The overall duration of the proposed audit

• The starting location and time

• The proposed scope and areas to be covered by the audit

• A timetable for approximate progress of the audit where applicable, e.g., if a number of different departments or geographical areas are to be included in the scope of the audit

• The arrangements for any close out meeting where the findings of the audit can be agreed and corrective action requirements discussed

• The personnel liable to be involved at each stage of the audit

If an auditor does not give sufficient attention to ensuring that clear agreement is reached with respect to the above points, the potential for misunderstandings that can affect the conduct of the audit is greatly increased. However, these initial communications with the personnel of the area being audited not only affect the “tone” of the forthcoming audit, but they can significantly influence the commitment and level of cooperation shown by that area throughout the audit process and for many subsequent audits.

Prior to commencing the audit, but once the plan is prepared, the audit team assignments are made, and working documents are defined. Working documents are those documents such as observation logs and checklists that are used during the audit to collect evidence, but are not necessarily retained as records. In other words, they may be discarded after the audit is complete and the report prepared.

Of these, only the checklist should require an input at this stage from the auditor. However, before compiling a checklist, the auditor must determine if the function and format of the checklist are prescribed by the audit procedure or whether personal preference can be exercised.

The format of the checklist may vary considerably, depending on whether it is intended to act as an aide or as a part of audit records showing the scope and conduct of the audit. The former may consist only of general topics to be covered during the audit, whereas the latter may be an extensive and detailed questionnaire on which details of sampling and answers to the questions are to be recorded.

The need for checklists and the type appropriate will vary according to other experience of the auditors and the culture of the company. It is recommended that for purposes of internal audits, checklists, even if limited, should always be developed. However, standard questionnaire type checklists not prepared by the auditor that must be slavishly followed and completed, should be

avoided. This latter type is likely to result in an unnecessary restriction in the scope of the audit and a stifling of auditor initiative.

Although an auditor should always work within the scope defined for the audit, the working documents must not be designed so that they restrict additional audit activities or investigations that may become necessary as a result of information gained during the audit. There are differences of opinion over whether it is preferable to create the checklist anew or whether a previously developed checklist can be used. Although the former is desirable in principle, it is not always practical in terms of the best use of the resources available. The best compromise is to utilize whatever available checklists are already in existence, but to review these critically

against the relevant documents previously identified. In this way, time can be saved in using them as a foundation without detracting from effectiveness.