View Full Version : To list the aspects or to hide it because of no control over it?
ganglai 13th February 2006, 01:52 AM We will have our ISO 14001 next month. But, I am in a big doubt now whether to list some of the aspects or not to, because we do not have a sound control over them. The auditor may either find that the control does not happen or the aspect is not identified.
I have to clarify that those ones are not so significant as spillage or something. But what about the selection of suppliers or raw material? We select our supplier or material based on prices.
Do we rather list it there without a control or not to mention it?
Thanks for your help.
Dr. L. Ramakrishnan 13th February 2006, 08:49 AM We will have our ISO 14001 next month. But, I am in a big doubt now whether to list some of the aspects or not to, because we do not have a sound control over them. The auditor may either find that the control does not happen or the aspect is not identified.
I have to clarify that those ones are not so significant as spillage or something. But what about the selection of suppliers or raw material? We select our supplier or material based on prices.
Do we rather list it there without a control or not to mention it?
Thanks for your help.
Dear Friend,
Your doubt gives an impression as though you are establishing an environmental management system for the auditor. Then you are wasting your time. If you are establishing a system for improving your organization's environmental performance, then this doubt will not arise. You should identify all the aspects that have impact(s) on the environment - indeed suppliers (their activity) and materials used have (significant) impacts on the environment. Depending on the procedure that you have developed, you may identify them as significant or non-significant. If identified as significant, you may address these significant aspects through one or mroe of the following: (a) by establishing objective, targets and programmes (4.3.3), (b) by establishing operational control procedures (4.4.6), (c) by providing appropriate training to personnel (4.4.2), (d) by proper communication (4.4.3)and (e) establishing a procedure to prevent (or act during) accidents and emergencies (4.4.7). If you have identified "Selection of suppliers" as a significant aspect, you may like to address this through (a), (b) or (d). Since the system is YOURS, you may decide as to how you are going to address this based on the available resources. By doing so, you not only meet the audit requirements, but also the intended purpose of ISO-14001 - i.e. improvement of your organization's environmental performance. By doing this you are also reducing the risk to your organization.
All the best to you for your ISO-14001 audit.
With best wishes,
Ramakrishnan
Randy 13th February 2006, 10:50 AM Well said Dr. R.................:applause:
SteelMaiden 13th February 2006, 11:27 AM Gotta go with the Doctor. Especially the part about it being your system. If there isn't anything you can do about it, then that is that. If there are things you can do, but it would be a long range plan then so be it.
Sidney Vianna 13th February 2006, 11:33 AM Dear Friend,
Your doubt gives an impression as though you are establishing an environmental management system for the auditor. Then you are wasting your time. If you are establishing a system for improving your organization's environmental performance, then this doubt will not arise. You should identify all the aspects that have impact(s) on the environment - indeed suppliers (their activity) and materials used have (significant) impacts on the environment. Depending on the procedure that you have developed, you may identify them as significant or non-significant. If identified as significant, you may address these significant aspects through one or mroe of the following: (a) by establishing objective, targets and programmes (4.3.3), (b) by establishing operational control procedures (4.4.6), (c) by providing appropriate training to personnel (4.4.2), (d) by proper communication (4.4.3)and (e) establishing a procedure to prevent (or act during) accidents and emergencies (4.4.7). If you have identified "Selection of suppliers" as a significant aspect, you may like to address this through (a), (b) or (d). Since the system is YOURS, you may decide as to how you are going to address this based on the available resources. By doing so, you not only meet the audit requirements, but also the intended purpose of ISO-14001 - i.e. improvement of your organization's environmental performance. By doing this you are also reducing the risk to your organization. I STRONGLY disagree with the inference of implementing an EMS by the so called "say what you do; do what you say" approach. If the external auditor knows what s/he is doing, they will test both the process for identification of aspects and significance determination. So, a competent external auditor will write you up for significance determination procedures artificially manipulated by the organization to obfuscate the real E risks.
To ganglai, my advice is: do the right thing and let the chips fall where they may. What you proposed is to do a mockery of an EMS implementation. A true professional would not thread that path.
ganglai 13th February 2006, 06:20 PM I STRONGLY disagree with the inference of implementing an EMS by the so called "say what you do; do what you say" approach. If the external auditor knows what s/he is doing, they will test both the process for identification of aspects and significance determination. So, a competent external auditor will write you up for significance determination procedures artificially manipulated by the organization to obfuscate the real E risks.
To ganglai, my advice is: do the right thing and let the chips fall where they may. What you proposed is to do a mockery of an EMS implementation. A true professional would not thread that path.
Thanks everybody. I learnt a lot from all of you in this forum. I will take the advice “do the right thing and let the chips fall where they may”.
But there is a strong voice from somewhere very close to me saying “I will do the audit in my way….let’s squeeze through the audit this time and we will… next time”
Paul Simpson 20th February 2006, 05:30 AM I STRONGLY disagree with the inference of implementing an EMS by the so called "say what you do; do what you say" approach. If the external auditor knows what s/he is doing, they will test both the process for identification of aspects and significance determination. So, a competent external auditor will write you up for significance determination procedures artificially manipulated by the organization to obfuscate the real E risks.
To ganglai, my advice is: do the right thing and let the chips fall where they may. What you proposed is to do a mockery of an EMS implementation. A true professional would not thread that path.
Sidney has it right again. You can't ignore an aspect because it is too difficult or expensive to deal with. You may recognize the fact that you can't affect the aspect and therefore not set any objectives and targets but need to be on solid ground to show reasons for selecting / not selecting a particular aspect as significant.
It is true you have to make the system your own but that only means you choose aspects that are truly significant to your organization - not that you pick and choose "significant" aspects based on what you feel like doing today.
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