Hi covers,

normal tools for communication of the environmental aspects or policy "for persons working on its behalf" (4.4.2) are information sheets or internet publications.

Do you have any other (more innovative) suggestions to manage these requirements?

Thanks
QMarc

P.S. It is a question arising from a german forum and there were only standard answers

The policy can be included in contract statements, as advertisements in periodicals, product sales materials and newspapers, and others.

Suppose a company wants to communicate to customers and potential customers that it is ISO 14001 registered and produces and distributes brochures that advertise its products and the fact that the organization is ISO 14001 before they are registered by a 3rd party.

Then suppose the 3rd party auditor comes along and discovers the brouchure during the registration audit and there is evidence that the brochure has been distributed to stakeholders.

What would a reasonable auditor do??

10 lashes with a wet noodle.

Good question. I'm actually in our corporate office today and I'll ask about this, I've never had it happen or even thought about it.

Suppose a company wants to communicate to customers and potential customers that it is ISO 14001 registered and produces and distributes brochures that advertise its products and the fact that the organization is ISO 14001 before they are registered by a 3rd party.

Then suppose the 3rd party auditor comes along and discovers the brouchure during the registration audit and there is evidence that the brochure has been distributed to stakeholders.

What would a reasonable auditor do??
It's an interesting question, but the original question was about communicating the policy, not advertising registration status. In the case you propose, there's obviously been some false advertising going on, but if the registrar isn't mentioned by name, and protected language/symbols aren't used, it should be of no concern to the auditor so long as the company's policy is compliant and has been adequately communicated.

I have had this come up. The guidance below touches on the the subject. To me it is saying that the registrar's procedures need to address what they would do in the above case.

I am interested to see what Randy comes up with.

IAF Guidance on the Application of ISO/IEC Guide 66
IAF Guidance to Clause 5.7. (G.5.7.1. to G.5.7.5.)

"G.5.7.1. The certification/registration body should have documented procedures for the use of its mark, and for the procedures it is to follow in case of misuse, including false claims as to certification/registration and false use of certification/registration body marks."

I have had this come up. The guidance below touches on the the subject. To me it is saying that the registrar's procedures need to address what they would do in the above case.

I am interested to see what Randy comes up with.

IAF Guidance on the Application of ISO/IEC Guide 66
IAF Guidance to Clause 5.7. (G.5.7.1. to G.5.7.5.)

"G.5.7.1. The certification/registration body should have documented procedures for the use of its mark, and for the procedures it is to follow in case of misuse, including false claims as to certification/registration and false use of certification/registration body marks."
I'm also interested in seeing what Randy says (as I'm always interested in what Randy says:D ). I think the language you quote is (typically) ambiguous, and seems to pertain to claims that include use of protected marks and references, and allows for the certification body to have a procedure that says, "don't worry about it."

and allows for the certification body to have a procedure that says, "don't worry about it."

Yep :agree1:

Hi covers,

normal tools for communication of the environmental aspects or policy "for persons working on its behalf" (4.4.2) are information sheets or internet publications.

Do you have any other (more innovative) suggestions to manage these requirements?

Thanks
QMarc

P.S. It is a question arising from a german forum and there were only standard answers

In getting back to the original question... This will probably raise some debate, but this is an important question.

Cl 4.2.f says an organization's policy has to be communicated. We need to consider what is the purpose for this requirement.

Cl 4.2 says an organization's policy has to include a commitment to prevention of pollution, obeying legal requirements, framework for setting objectives and targets. The policy frames the expectations an organization has that its employees will carry themselves in such a way as to meet the organization's "policies."

If Cl 4.2.f says the policy has to be communicated to other people working on its behalf, what would be the reason for this requirement? Because these other people haven't gone through the company's training and EMS system implementation, but somehow, we still want them to carry themselves in such a way as to meet the organization's "policies" to be environmentally aware and prevent pollution, etc.

So, however we communicate it, this communication needs to be likely to result in subcontractors understanding and doing the right things as well. Otherwise, it is not effective, and adds no value.

This intent is further reinforced in 4.4.2 when it says these other persons are competent, etc... We're trying to prevent pollution caused by employees or nonemployees who are doing things on our behalf.

We need to communicate our expectations, and whatever else is needed to ensure they are likely to perform according to our expectations. We also want to keep it reasonably brief, and easy to understand, so it works but does not get in the way of the job we asked them to perform. This is actually a challenging requirement, not just a stack of flyers lying in the lobby.

Isn't the reason to help ensure that the subcontractor also performs in a manner consistent with the organization's policy?

@hjilling

This is exactly the reason for my question.
My interpretation of 14K is to get the stame standard for contractors as for the own company.
Is it still enough to communicate the policy, targets and objectives?

In my opinion no. I think you should also have a look to the persons working on behalf and check the level of conformity with legal requirements for example.

Isn´t that also the idea of 9001 to evaluate suppliers quality standard with supplier audits?

QMarc

@hjilling

This is exactly the reason for my question.
My interpretation of 14K is to get the stame standard for contractors as for the own company.
Is it still enough to communicate the policy, targets and objectives?

In my opinion no. I think you should also have a look to the persons working on behalf and check the level of conformity with legal requirements for example.

Isn´t that also the idea of 9001 to evaluate suppliers quality standard with supplier audits?

QMarc

This latest post can be tied to 4.3.1 where we see the "control and influence" language, and in 4.4.6c where goods and services of suppliers and contractors is specified.......


In answer to the original question and after some head scratching here's what "WE" came up with....as long as they didn't specify the CB in the statement what we have is a challenge to their veracity, but not an N/C. Now if they state their EMS just "conforms" to the requirements of 14001 technically "no harm-no foul". We definitely would have some questions. (One of our ... I'm trying to be gentle...... SR individuals who lets say isn't prone in his home country to celebrate the 4th of July....believes we would be best served to toss a client that ventures from the truth as you originally put it in the example. I also posed this "hypothetical" to my EMS Lead Auditor class that I'm presently instructing and they pretty much came to the same conclusions that some of the folks around the office provided above.

That's the best I can give ya right now.

@hjilling

This is exactly the reason for my question.
My interpretation of 14K is to get the stame standard for contractors as for the own company.
Is it still enough to communicate the policy, targets and objectives?

In my opinion no. I think you should also have a look to the persons working on behalf and check the level of conformity with legal requirements for example.

Isn´t that also the idea of 9001 to evaluate suppliers quality standard with supplier audits?

QMarc

Communicating it is compliant. You have to decide if it is enough for your needs.

In 9001, supplier audits are not required by the 9001 standard, but are certainly allowed. They are one option, but not the only option. Apply the best tool for the job. Evaluate them, and if you feel an audit would be beneficial, then do it. On another supplier, you may decide it is not needed, then don't do it. Select the best tool for each job, I say.

Helo QMarc,

Could you pls provide me your email address, I would be able to send you a sample/samples which might of interest to you.

@pmwong

If you are a registered user ... and you seem to be ... send me an E-mail to the adress included in my profile.

QMarc

send me an E-mail to the adress included in my profile.All you need to do is to click any users name: Unless the user has disabled this function you will now see a menu with (among other things) the options to send a private message or email. You will not see the mail address, but sending a mail to the user will of course reveal your address to the reciever.

/Claes

QMarc,

I have forwarded the address.