I have found that sometimes an auditee will do a good job of listing aspects but misunderstand the designation of significance. They sort of play a game with this and try to artificially limit the number of aspects they identify as significant. They believe this will help them in the audit because they only have to manage the aspects that are significant and they can only be audited on significant aspects.

During the audit you find that there are operational controls in place for insignificant aspects but because they are insignificant you cannot assess these. In cases like that I am tempted to write in the report;

The auditee appears to have chosen to limit the number of aspects identified as significant with the purpose of limiting the scope of the EMS audit. This has resulted in some aspects which should be considered significant to be excluded from the EMS thereby diminishing the effectiveness of the system.

I know this would upset some auditees. The truth hurts. Any comments?

I understand where you are coming from, but I tend to be more "liberal" and look towards the "spirit" if not the "letter" of the standard.

Doesn't the system belong to the auditee?

Does the auditee not have the right to determine what are and what are not aspects and which ones are significant?

Doesn't the auditee not have the right to determine how it will address or control aspects, significant or not?

I tend to think that my job is to determine whether or not an auditee is stating what will be done, doing what is stated and providing objective evidence for the performance based upon the requirements of the standard.

I may have missed the portion of my LA training where I am to judge the efficiency or effectiveness of the system. In fact give me some time and I will try to identify where those requirements are in 14001:1996.

We have the possibility of a great topic here. I hope some others join in.;)

They sort of play a game with this and try to artificially limit the number of aspects they identify as significant. They believe this will help them in the audit because they only have to manage the aspects that are significant and they can only be audited on significant aspects. Ok.. We have to have procedures to determine which aspects are significant and possible to control. That way we set the bar. Following the procedure will give us a number of significant aspects. Fiddling with the procedure can change that number.

Now: How many significant aspects are you able to handle (Resources)? There is a limit to what the organisation can cope with. The number of significant aspects should reflect that. If all goes well we will have a different situation next time we identify our aspects (improvement on the chosen aspects). We should then be able to raise the bar and attack other aspects or set new targets for the previous ones.

Continual improvement....

/Claes

Well I dont know ISO14001 in great depth but to me it seems unacceptable that a company could, for example, be pumping raw sewage into a river, but not have to do anything about that because it has chosen not to list it as significant.

If this kind of rationale in choosing aspects and considering impacts is not in ISO14001 then the standard is a complete load of old cr.........

Well I dont know ISO14001 in great depth but to me it seems unacceptable that a company could, for example, be pumping raw sewage into a river, but not have to do anything about that because it has chosen not to list it as significant. Ah.. But they can't... That would mean two things:
[list=1]
They would have so many more significant aspects that they didn't have the resources to adress that problem.
They would be breaking all kind of laws and concessions
[/list=1] In short: A company like that would never be able to get a certificate.... and I very much doubt if they would be permitted to run their process at all.... anywhere.... What I'm talking about is to use your available resources in the best possible way: Go for your worst aspects first, which is basically just common sense.

/Claes

The identification and control of aspects is where a lot of non-environmental professional amatuers can cause havoc.

Most people don't know that in the USA any company with the proper permit, issued by the appropriate agency, can pump, discharge, drain or dispose of anything, anywhere.

An aspect, that is being controlled by a permit of sorts, may be considered as not significant by the organization as long as they stay within the permit parameters.

I also seem to remember something like "the aspects related to these significant impacts are considered in setting its environmental objectives." The word "considered" is the operative word here. You can "consider" something without doing anything else and be right. "Consider" means to think about, to weigh it, to judge, to take into account.

Question during an audit "Did you consider X when establishing your O&T's?"

Answer "Yep....we considered it, but we had other pressing issues, which are outlined in our Management Review records."

Nuff said I think.

Unless I've misunderstood what kalehner has said, it appears that the company isn't ignoring these aspects, only that they are artificially limiting the scope of the audit by not including them as "significant aspects".

The controls are there - so the company is applying resources and obviously they consider the aspect significant enough to have established these controls. Why have they excluded them from the scope of the audit?

A registrar auditor can, and will, write up "significant" tests that are cr@p. And if I recall correctly, it did have to do with "effectiveness".

Most people don't know that in the USA any company with the proper permit, issued by the appropriate agency, can pump, discharge, drain or dispose of anything, anywhere. Ouch..!

Errrr.... That was not quite what I had in mind, of course. I didn't expect that.

/Claes

Kinda scary isn't it Claes?:eek:

Originally posted by Randy
An aspect, that is being controlled by a permit of sorts, may be considered as not significant by the organization as long as they stay within the permit parameters.
I can't agree with this statement Randy. While it appears that companies are at liberty to use whatever criteria they see fit as a test of significance, for all practical purposes any permitted activity will be a significant aspect by any test. It is not a defensible position that while the aspect is significant to the law and to environmental concerns outside of the company's doors, it is not significant enough to the company to establish and maintain controls within the context of their EMS.

It just ain't gonna happen.

And just because I feel a little bit ornery this morning, I will also point out that it may be considered not significant "as long as they stay within permit parameters", is not anywhere in auditing criteria. So just wondering why you would make that exception, and how you could reasonably expect the company to address this need to stay within permit parameters without including the aspect in their EMS. ;)

"Here is our aspect list, and here are the ones WE consider significant." "We (the organization not the auditor) reserve the right to determine which aspects are significant, the method for doing so, and how we will control them." "We will CONSIDER those aspects which have a significant impact on the environment when setting our O&T's but WE reserve the right to address those which WE truly can control or have an influence over."
"It is our intention to continually improve our environmental performance and address all of our aspects in due course."

Where are the statements above incorrect?:confused:

Who kicked the bees nest this morning?????

I'm new to the 14000 stuff, only been registered since Dec. so this is a great learning thread for me.

My questions:

I show you how I designate "significant" (FMEA RPN system) and the ones I have controls on are not deemed significant by my score system. Is that considered "artificial limiting" the audit scope?

Do you as auditors feel you should/could write NCs because I don't put enough emphasis on an aspect even if it within my described program parameters (i.e. waste oil salvage).

I'm very interested in this, we are very "Low Key" when it comes to 14000 and I fired a registrar due to the issue with these questions. He didn't feel we were "looking deep enough" for our significant aspects. :confused:

Originally posted by Randy
The identification and control of aspects is where a lot of non-environmental professional amatuers can cause havoc.

Most people don't know that in the USA any company with the proper permit, issued by the appropriate agency, can pump, discharge, drain or dispose of anything, anywhere.

An aspect, that is being controlled by a permit of sorts, may be considered as not significant by the organization as long as they stay within the permit parameters.Randy,

You can kind of include me in that group.:bonk: This significant aspect thing....When a company decided to obtain a waste discharge permit, wasn't the discharge considered significant at that point? Does significance diminish as you become more confident in your controls? Just asking.

We are currently permitted to discharge 235.000 gallons a day of waste water used to regenerate resin for use in water treatment into a POTW. Diluted hydrochloric acid and potassium hydroxide used to keep the discharge within ph discharge limits. Our average daily discharge for a month is approx. 9000 gallons. There are limits on the ph, the amount per day as well as monthly average which differs significantly from the 235, 000 max daily limit. Actually 78,000 average monthly flow. All this is completely PLC controlled. There are 5 ph probes. If just one fails, the system shuts down with spring closed valves. No discharge can occur until all settings are obtained. Would you say that because we stay within our State Discharge Limits and we have built in failsafes, that they wouldn't have to be considered a significant aspect any longer? Just asking. :ko: :smokin:

I know of a company that routinely does not meet certain permit requirements. Yet they have determined the aspect is not significant! Their registrar is okay with it! I have a real problem with this. In my limited mind, in permitted situations the aspect has to be significant. If it is significant for the government to regulate it, it must be significant. The organization’s controls might be limited to the actions they take to keep within limits, but I can’t see how anyone can justify the aspect is not significant!
:mad:

My opinion…now your turn.

Do you as auditors feel you should/could write NCs because I don't put enough emphasis on an aspect even if it within my described program parameters (i.e. waste oil salvage).

I'm very interested in this, we are very "Low Key" when it comes to 14000 and I fired a registrar due to the issue with these questions. He didn't feel we were "looking deep enough" for our significant aspects.

Randy...Are you managing your system I/A/W the standard and the way you say you will? To me it seems as if the registrar was wanting to be the manager also. Continue with your business and continually improve your processes. By doing so your environmental performance will also improve. Improvement of environmental performance is the goal, not perfection.


Energy......The determination of significance rests with the organization and not the 3rd party. I recently implemented a 14K program for an organization that had a ground water plume of perchlorates that stretched for 20 miles into the LA basin area. They did not list it as a significant aspect because it was already being controlled under agreement w/the Cal & Fed EPA, costs were being born by another company and they had no control over any aspect of the operation (even though the plume started under their property from previous internal operations) The registrar/auditor bought off on it and said it was not an issue and found no fault in the methodology.

I'm not saying to ignore the waste stream, there is frequently room to improve on process to reduce discharges. I'm saying why should organizations be required to get wrapped around the axle over issues that cannot be resolved further and are being controlled by best business practices and according to law.

Prevention of pollution can never be totally arrived at, only addressed.

Yes I am Randy.

I got the feeling from the auditor that he didn't trust us, like he felt we were snowballing him. I understand that what we score as significant is chump change to others (i.e. laser toner cartridges, dry cell batteries etc.) but we are mainly an engineering firm. He was looking for more meat and potatoes and we were serving appetizers.

My take on 14000 was that it started or covered things not covered by permits, Legal and other requirements and OSHA.

Stew, I was at a HQ (similar to engineering firm). We were discussing aspects when one of the guy's mechanical pencil lead snapped quite loudly. He brushed the broken lead on the floor, which lead to a discussion on whether the discarded lead was an aspect. Although it was an aspect, is it important to even list? Probably not.

You are right. Most auditors want to three course helpings in aspects, and all you have is some celery sticks. This company’s most significant aspect was electrical usage. How boring!

I can understand that. About the pencil lead...... Last month we had our 1st lost time injury in the Design Engineering Dept. You guessed it, he got pencil lead stuck in his hand and it got infected bad enough to have his hand bandaged so he lost 2 days!!!!!

db,
I don't mind an auditor looking to see if I've covered everything, (I guess that's what internals are for too) I just don't care for the digging!!!!

db.....electrical usage is one of the more common aspects and one of the most important, both environmentally and financially. As far as I'm concerned, it should be on nearly everyones shortlist, but if it's not I'm not going to have a hemmorage over it.

Squidly (Randy).....I can't remember an auditor trusting the auditee as a requirement during my LA training....I remember it being the other way around. As an auditor I too become part of the system and can be improved upon if the situation warrants. You manage the syatem and the auditor verifies based on OBJECTIVE evidence. The auditor must 1st and foremost be OBJECTIVE regardless of his/her personal feelings, beliefs or passions. If your auditor wants to start going off on tangents then start playing 20 questions to determine the true environmental management competence of the person. If they wanna "talk Sh--" then start "talking sh--". In most cases getting back on track will become the object.

Randy

Forgive my ignorance on this subject, but i try to understand it by drawing parallels with ISO9000 - maybe I am wrong for trying to do that.

But when you say the company decides what is significant I cant help feeling that it is like a company deciding what a customer wants of its product/service in a QMS context. We all know that in our QMS we need to listen to our customers predominantly, as they set the requirements for our products, we also have regulatory requirements set by governments, and if we use ISO9004 we probably also listen to other interested parties such as stakeholders. My point being that what is significant for our product is detemined by external forces, we do not decide. Wouldnt this also apply to environmental issues, with the larger emphasis being on regulatory issues ?

Claes made the point that in my exaggerated analogy that I would be breaking the law. Sure but in the context of ISO14001 requirements would I comply ?

Really doesnt seem right to me.

P.S. I am no tree hugger either (before you start energy :vfunny: )

I know it isn't a prereq but on the otherhand you don't call me a liar because you don't understand our business or system!!!! If you look at 4 or 5 examples and can't find anything, do you ask for 10 or 20 more?

This guy went from me (Mgmt Rep) to the ISO Champion, to our Core Group Leader and when he was on the floor he was trying the trick question routine. It was more like an interrogation. I have dealt with 3 different registrars, and approx. 35 different auditors, since I started in QA back in '88 and I have never had one take off to the restroom and end up on the shop floor for a 1/2 hour w/o a company rep with them. This guy did. If there had been 2 of them we would have had good cop/bad cop Randy!!!
The next one out was fine, we had our arguements but that's part of my job.

:cool:

I feel sick.:ko:

I've tried to respond twice already but each time I hit the post reply button I find that I've timed out and have to log in again. Used to be that the post would post under "unregistered" but now it won't post at all and there's no getting back to what I've written! :frust:

So you are spared my eloquent words of wisdom. For which you are no doubt grateful.

I will simply say that effectiveness is fair game for certification audits - not just having the literal text of the standard covered- and that you-betcha the auditor should be interested in the adequacy of the significance test. Our auditors encountered poor significance testing many times and yes, the company would be informed that it was a problem. Except for rare circumstance ( and dare I say upon poor advice from a consultant? *duck*!) the company was simply uninformed and unaware of the various ways to do it "correctly".

When a significance test is developed to limit the company's active implementation of an effective EMS, management commitment is lacking and this will be cited.

In who's opinion? The only one that counts = the person issuing the certification.

Don't quote the standard and ask "where does it say that?" Certification uses other criteria than just the standard. IAF guidance documents, accreditation requirements, etc.

You have a good point Lucinda. The "Standard" uses other criteria that we need to be aware of but aren't.

An auditor should look at adequacy, I don't argue that, that's really the whole point isn't it? But who defines what is considered adequate??? The other documents you sited that I may or may not have access too?

This is where I get into my arguements. The last auditor hit me for a few things I've posted in earlier threads. When I questioned the validity she told me it wasn't spelled out in the standard but she boss required it. Where's that coming from, I don't have access to their corporate rules!!!

I don't mind working on things that will help, I don't mind being told I'm wrong (sometimes):D , but I'm too old to hear "Because I said so" and not ask a question!!!:eek:

:ko: :frust: :smokin: :bonk:

A while back we had a thread dealing with the identification of aspects and how to determine significant ones. Quite a few of the folks that contribute here provided a variety of insight in how they or their clients do so. The remarkable thing is...everybody was right in what they said and provided.

There are no rules, set in concrete, on how significance is determined. The person that started this particular thread (klehner) and I even shared comments about my "Chicken Bone" theory.

There are many different ways to determine significance and taking into consideration environmental regulations is only a small portion of the total methodology.

As an organization you determine your parameters, your procedures and then go for it, just be able to provide objective evidence that you have done so.

I will say this however....not addressing current processes and practices that contribute to pollution, waste, consumption of resources and regualtory issues as significant, to me Randy the person and environmental professional, is a waste of effort and diminishes the intent of the standard.

But then again most of it is really just smoke and mirrors, catch as catch can, and hum-bug. verry, very few modern organizations really care. For the most part EMS's are implemented for financial issues more than environmental preservation ones. There are just too very few people in positions of substantial influance to say that. So what will happen is, organizations will continue to do the EMS and EMAS and Responsible Care and all that other stuff hoping that everybody else gets the same warm fuzzy they do and puffs on the same Crak pipe.:eek:

Let me preamble my comments by stating that I am NOT an environmental professional, but Registrar's auditors need to assess the meaningfulness of the methods used by the organization to determine significance of aspects. Let me offer the following piece of documentation to support that.

IAF Guidance on the Application of ISO/IEC Guide 66

G.5.3.21. Recording and evaluation of environmental aspects and control of those deemed to be significant.

(a) In order to provide confidence that organizations are consistent in establishing and maintaining procedures for the identification, examination and evaluation of environmental aspects and their associated impacts, certification / registration
bodies’ procedures should reflect the following factors:

- it is for the organization to define the criteria by which environmental aspects and their associated impacts are identified as significant, and to develop (a) procedure(s) for doing this;

- it is for the certification / registration body to assess that the procedure(s) by which the organization determines which environmental aspects and their associated impacts are significant is sound and adhered to;

(b) The certification / registration body should establish whether the procedures employed in the analysis of significance are sound and properly implemented. It shall verify that an environmental aspect or associated impact which is identified
as being significant is managed within the system. . . .

(c) Significant environmental aspects and their associated impacts are not necessarily confined to a single geographical location. They may also include other aspects of an organization’s activities, products or services that it can control and over which
it can be expected to have an influence. In particular, these may include any activities of suppliers, customers or related organizations which create additional environmental aspects for the organization.


So EMS auditors are supposed to challenge the adequacy of the methods deployed to determine significance of aspects, and not just verify that the organization has one.

PS Before being accused of flaming or blasting anyone, let me say that this reply has no accusatory tone. It is not intended to reply to ANY specific contributor or post on this thread. It is just meant as sharing knowledge.

Really!! Tell me Sid what does "sound and properly implemented" mean?

What does it mean to a regulator?

What does it mean to a lay person?

So EMS auditors are supposed to challenge the adequacy of the methods deployed to determine significance of aspects, and not just verify that the organization has one.

Based on your above quote there are a whole bunch of EMS auditors running around that better have the moxy to make a better challenge than "just because I think so". They better be able to back up their "feelings" with more than an EMS-LA course as their environmental training and the performance of audits as their sole experience. And beyond knowing some whiz bang EPA mumbo-jumbo here in the states those same auditors better be able to tie in OSHA requirements that directly relate to an EMS.

I suspect very few can.

PS It was 95 here today Sid. How was the weather on the coast?

Also...this has been a great thread Kevin:bigwave:

I think we should leave regulators and lay people out of the picture, since they are not representing the certification bodies. Because it is the registrars responsibility to determine soundness of the procedure (according to the IAF Guidance document), the registrar must deploy auditors that are competent and qualified to make the judgement. Sound means that the method is meaningful, thourough.


I fully agree that there are many EMS auditors out there that might have the "certificate", but not the competence to be effective EMS auditors (remember my analogy that a drivers license does not make anyone a good driver?). In my opinion, the accreditation agencies have missed the boat BIG time, when determining the qualification/competence requirements for EMS (and QMS) auditors. But that is a whole new thread, called the trivialization and banalization of management system auditing. :mad:

Since some organizations might want to artificially limit the number of significant aspects to only those they have resources to control, instead of the other way around, external auditors need to be able to explain why they are questionning the organization's procedure. Without this type of integrity check, we will have more and more of the "drive-by-certificates", and the EPA more ammunition to use against 3rd-party EMS certifications.

Randy, I am trying to understand exactly your point. Are you advocating the much-so-maligned-overly-simplistic-pet-peeve-of-mine approach that ISO 14001 (as for ISO 9000) is simply do-what-you-say-what-you-do? I hope not.:bonk:

It was cool here in Long Beach. 61 deg. F. +- 5
And I agree with you. This is a great thread. Very interesting perspectives.

Martin wrote:Claes made the point that in my exaggerated analogy that I would be breaking the law. Sure but in the context of ISO14001 requirements would I comply ? Nope.

Your environmental policy must include a commitment to comply with relevant environmental legislation.

When identifying your aspects you must consider the applicable legal requirements.
When establishing your objectives you have to consider legal requirements.

No.... I can't see how you could break environmental laws and still comply....

/Claes

P.S. Brilliant discussion.. It has enhanced my understanding of ISO14000. It's a good thing when you're forced to think things through.

Sid,
You Stated, "Since some organizations might want to artificially limit the number of significant aspects to only those they have resources to control, instead of the other way around,"

Except for the word"artificially" I think if you read para 4.3.3 it says we should consider our financial resources.

Allowing auditors to make judgement calls on whether or not my process is suitable and effective is fine with me, as long as they state their opinions in the form of an opportunity for improvement.
Otherwise they should stick with the purpose of the audit, which is to determine if the process. conforms to the requirements. Auditors should not be in the business of telling us how to do the job, only whether or not we have complied with the requirement.

BTW i am not an expert either. Although we have been registered to ISO14001 I have not attended any classes, auditing or technical.
So my opinions are just that.

Randy, I am trying to understand exactly your point. Are you advocating the much-so-maligned-overly-simplistic-pet-peeve-of-mine approach that ISO 14001 (as for ISO 9000) is simply do-what-you-say-what-you-do?

Not really so much that, even though it may sound like it from time to time. What we have to do though is be cautious about how critical we are so we don't overstep the boundaries of auditing to consulting.

We need to ask ourselves, "What is the true intent of the standard?" Not being privy to everything TC207 did and talked about I can only surmise that the intent is to provide a framework for any organization to use to manage its environmental performance. One of the major inclusions in the standard is that of continual improvement.

The failure to identify significant aspects, whether intentional or not, provides an opportunity to improve. The problem here is that I firmly believe there are too few EMS auditors out there that actually possess the skills to be judgmental in this case. I can think of a couple aspects right now that are never included, but are real, may be contributors to significant impacts and may or may not be controllable depending upon the situation. Because I have this knowledge doesn't give me the right to body-slam an auditee for not identifying them. Then again if I detect that an auditee may be trying to pump sunshine up my butt I will most likely take issue and dig a lot deeper.

Trust me when I say that there will always be some written verbage for any organization if I think there is room for improvement.

It was 32 here yesterday and it snowed all day. They say it will be cold until the weekend . Wonderful spring Wisconsin weather! Thanks for the positive comments on the thread. I guess when I posted it I was thinking about a more subtle auditing issue of how do you tell an auditee that they kind of missed the boat on their aspects without necessarily writing a nonconformance.

Lets say I am doing a registration assessment and the auditee has a documented aspect identification procedure that used some type of FMEA approach to determining significance on a comprehensive list of aspects. They assign a value (based on criteria like severity of failure or potential for failure to occur etc.) to each aspect then compare this value to a significance threshold value. So far so good right?

The line of questioning then turns to how they determined the significance threshold and they quite honestly answer that we decided we only wanted to manage 5 significant aspects so we chose the threshold value that would give us that number of significant aspects?. Or they dishonestly (I suspect) answer, We don't know. We just thought that would be a good cutoff value.?

Now I have objective evidence and need to make a call on weather or not the procedure implemented meets the minimum requirements of ISO 14001 and at this point I see no evidence that their aspect identification procedure does not meet the requirements of ISO 14001.

Later when auditing operational control 4.4.6 I discover that they have documented procedures for periodic inspection of hazardous waste storage areas and for management of waste light bulbs and waste batteries but none of these aspects have been identified as significant because they did not exceed the significance threshold established by the FMEA procedure. I also find that they are not following the documented procedure they have established for waste batteries storage and that this documented work instruction has never been and is never scheduled to be audited during an internal audit.

Now I have to make another decision. Is the nonconformance with a documented waste battery work instruction a nonconformance under 4.4.6? Not being a significant aspect I am not sure I can write a nonconformance to it. The other problem I have is that the waste battery storage procedure has never been audited. Is this a nonconformance to 4.5.4 EMS Audits? Again, probably not. The standard does not require insignificant aspect to be included in the internal audit schedule.

But there is a problem here right? It has to do with the effectiveness of the system and the adequacy of the aspect identification procedure. I think Sidney hit the nail with his reference to Guide 66 G.5.3.21. (b) The certification / registration body should establish whether the procedures employed in the analysis of significance are sound and properly implemented.

Individually each of the above problems would not by themselves lead to a nonconformance to ISO 14001 but together I believe I may have enough evidence to make a finding to 4.3.1 Aspect Identification as follows:

The procedure used to identify environmental aspects is not effective in determining which of these aspects can have significant impacts on the environment?.

Now the question is what kind of finding is this, major nonconformance, minor nonconformance or an observation? Has this nonconformance caused a system failure? Does the auditee need to implement a corrective action for the nonconformance or should the auditor leave it up to the auditee to determine if a corrective action is warranted? Comments?

Kalehner,
This statement; "It has to do with the effectiveness of the system and the adequacy of the aspect identification procedure. I think Sidney hit the nail with his reference to Guide 66 G.5.3.21. (b) The certification / registration body should establish whether the procedures employed in the analysis of significance are sound and properly implemented."

Coupled with this statement; "I believe"
IMO is why a third party should not judge on the suitability and effectiveness or as you put it "sound and properly implemented" of the process.

Kevin right off the bat you have them for failure to comply with regulatory requirements 4.3.2 for improper management of hazardous waste. They must have procedures dictated by 40CFR260-266 most likely 40CFR262 Standards Applicable for Generators of Hazardous Wastes. Even though the battaries may not be a RCRA waste they are most definately a Universal Waste and must be properly managed. As a waste stream the containers that hold them are required to be inspect at least every week and records maintained of the inspection. Also records of transportation and disposal must be maintained. You can also check on the training of the individuals that manage and handle the wastes.

Based upon there aspect procedure the waste materials may or may not be considered significant and I don't get heartburn from that. But if they are in an area that has a problem with mercury contaminated water, fish and all that crap then I would question the results of their procedure.

PS ... A really good thread Kevin

I've tried to respond twice already but each time I hit the post reply button I find that I've timed out and have to log in again. Used to be that the post would post under "unregistered" but now it won't post at all and there's no getting back to what I've written!
Here is a tip for you. I write the stuff first in Word, then cut and paste. Word also has spell check, which I need quite badley. That way if you get booted out, you can easily repost.
:bigwave:

From Sam:

" . . IMO is why a third party should not judge on the suitability and effectiveness or as you put it "sound and properly implemented" of the process. . . "

So, are you saying that Registrars should disregard ISO Guide 66 and the IAF Guidance on Guide 66? If that is your point, you are basically stating that the accreditation process and requirements need NOT to be followed.

Sid,
I believe what I stated was that an auditor should not be making judgement calls on the extent to which I comply with the requirement.(or something close to that) As I stated if an auditor wants to submit a subjective opinion then it can be done in the form of an OFI.
As far as guide 66, I don't know anything about it. It's not part of the standard nor is it part of the requirement for certification.

Sam, you are obviously entitled to your opinion. However, auditors HAVE to make JUDGMENT calls. ALL THE TIME. That is the primary reason they are expected to be competent to perform in that role.

The "roll-over, play-dead, rubber-stamping auditors" are as much part of the problem as the "my-way-or-the-highway, inflexible, ignorant, unresponsive auditors".

And concerning ISO Guide 66, it does affect how Registrars are supposed to perform and conduct their environmental management system certification business, thus, indirectly affect the certified organizations. This idea that because is not in the standard does not concern me, needs to be re-thought. Case in point, everybody agrees that results of audits are supposed to be based on "objective evidence". Where does objective evidence come from? It is NOT in ISO 14001, nor ISO 9001. Look in ISO 10011 and 14011 to find mentions to objective evidence. So, you might not be concerned with ISO Guide 66, but any qualified auditor performing an accredited EMS audit of your system is being affected by that document.

If you expect your external auditor to disregard Guide 66, you are basically expecting them to bypass the accreditation requirements that should boost confidence in the validity of the certificate that they will issue for you.

Hi all, I have been browsing the Forum for upwards of a couple of years now & just recently decided to register.

In response to Kahlener's comment, the interpretation of 'significant' was crucial to me when interviewing potential Registrars. In my view, all aspects have some degree of significance & are in the scope of the EMS. If there are sufficient operational controls in place for any aspect, that can reduce its potential or actual impact & thus justify it being considered non-significant.
I consider significant aspects to be those whose potential or actual impact require the setting of an objective & target as well as an environmental management program. Over time, as more operational controls are put in place to reduce risk, an aspect could change from being significant to non-significant but it would never drop out of the scope of the EMS. If a Registrar didn't agree with this approach, I wasn't gonna hire them!

I also agree with Lucinda that any legal/permit activity is significant, and this goes right back to the Policy requirements of"commitment to comply..." and "appropriate to the nature, scale..."

Anyway, just my two cents worth from a new kid on the block.

Rob P. Thanks for your comment. In the work I do as an environmental professional I wear three different hats, the consultant hat, the trainer hat and the auditor hat. When wearing my consultant hat and training hat I try to convey the notion to clients and students that a significant aspect is something that is on your EMS radar screen?. Significant aspects are things you intend to DO something about. I go on to tell them that there are three things you can DO with a significant aspect. You can set an objective and target to STUDY it to try to figure out what a good objective and target might be for that aspect. If it is low hanging fruit, you can establish an objective and target to IMPROVE it (ie replace a flow through water cooled compressor with a high efficiency air cooled one) or you can create an operational CONTROL to make sure the aspect is managed properly (ie hazardous waste accumulation area inspections etc).

When I wear my auditor hat I cannot expect the auditee to have the same view of significant aspects identification process as I do. The problem I have with not calling an aspect significant for which there is an operational control in place is that I have seen some organization simply ignore these aspects when it comes time to do internal audits. The operational controls in place are not audited because the aspects are considered to be insignificant.

Using the radar screen analogy, significant aspects are clearly visible on the screen because they are significant. The truly insignificant aspects are not on the screen at all. Insignificant aspects with operational controls are dim on the radar screen and there is some uncertainty as to whether they are something the organizations is managing and actively tracking or are they phantoms that we see but are not sure if they are important?

As an auditor I much prefer to see clear bright images on the radar screen. Dim potentially phantom images are confusing for me and I believe for the auditee. Many probably disagree with this approach but I have found that audits (that I have observed, not performed) of organizations with clear unambiguous radar screens go much better then audits with confusing radar screens.

I read through the “chicken bone thread” before I start to identify the environmental aspects. I agreed with Randy that the organizations reserve the right to set their own “consideration/ criteria” to identify the “significance” of an aspect.

Of course, it is undeniable that the “criteria/considerations” set by the organization must at least include:-

(1) the significance/ severity of the impacts caused by the aspect (after taking into account the likelihood)
(2) the legal requirements associated with the impacts/ aspects

On my opinions, basically, we can assume that the aspect which could cause significant impacts and subjected to legal requirements shall be considered as “significant”. But, if the organization already has “good control system” in place and “good compliance record” for the particular aspect. Then, of course the organization can assign the aspect as “not significant”.

In that case, means that the organization shall add another “criteria/ consideration” for their evaluation:-

(3) the current control practice (some sort like this)


My idea can be illustrated as the flowchart: (can not post, need to refer attachment)

After, the flowchart can be expanded and improved further.



:cool:

:frust:

there is a small mistake in the flowchart attached, anyway, i hope you can understand what i trying to say...........

I like this thread, i think i will print out the content and make it as a training material and discussed with my committee member.

;)

The "chicken bone method" was my way of being whimsical. I 1st propsed it when trying to explain how significance is determined to a bunch of rocket science Phd's (no fooling). Though I don't actually recommend the method, it does illustrate the point as to how arbitrary this procedure can become.

The real sticky point is, what truly is significant? Significance is like beauty... in the eye of the beholder.

Significance can be equated to firearms. In many areas of the Southern and Western USA it is very common to see folks driving around in pick-up trucks with gunracks in the back window and a rifle or shotgun fully displayed. In these areas this is not a "significant" issue or anything to draw interest. But imagine how the same act would be viewed in the Northeast and other major metro areas. The "significance" of this conduct would instantly draw attention and require corrective action.

The same reasoning applies to the environmental impact significance of aspects. Significance is in the eye of the beholder, or better said "significance depends on what the organization thinks is significant within specified guidelines and criteria".

When a 3rd party tries to impose its will on an organization it moves from objectivity to active participation. There is a fine line that has to be walked, and is very easy to cross. I believe that is one reason why continual improvement and management review are so very important.

Continual improvement allows corrective action to occur at a pace dictated by the organization. Management review allows, in fact requires top management (lower and mid-mamagement too) to re-address the system and all its elements. Another set(s) of eyes so to speak.

You keep on your track June, you're gonna do fine.

Originally posted by Randy Stewart
I got the feeling from the auditor that he didn't trust us, like he felt we were snowballing him. I understand that what we score as significant is chump change to others (i.e. laser toner cartridges, dry cell batteries etc.) but we are mainly an engineering firm. He was looking for more meat and potatoes and we were serving appetizers.That's sorta what I get with the small companies I am working with. We're down to soda cans (most of the drivers take them with them so there's not many anyway), also toner cartridges, printer ribbons., etc.

Originally posted by Randy
[B]When a 3rd party tries to impose its will on an organization it moves from objectivity to active participation. [B] No, it is not an imposition and there is no participation. The 3rd party isn't requiring the org to do anything. The org simply won't meet the criteria for certification, and that is entirely their own choice. Certification is not a given right - it is an award based on meeting certain criteria. And yes, some registrars may use auditors who look deeper and more critically than auditors from other registrars. ( which is no secret ). There is always a value judgement in whether something meets the letter and/or intent. Just because the org thinks they have meet the requirements doesn't mean that the registrar who is charged with actually confirming it, is supposed to just hand over a cert. It is the registrar's opinion of whether an org has met the requirements that enables a cert to be awarded.
The company is always free to do whatever they want. Including finding a registrar who will willingly sign their name to a lackluster system.

Because this point seems to keep getting lost, it bears restating : certification is based on the outside party's confirmation that the org meets requirements - not on the org's opinion that it meets the requirements. That is what you are paying for. Your own opinion of your system matters squat when it comes to certification. Of course you are always free to do whatever you want to with your system - just as long as you aren't expecting it to be certified.

Using that line of thought the company Marc is discussing in the thread "ISO 14000 in Trucking" could have a hard time earning a cert if an auditor wasn't happy with the lack of SA's.

I find it hard to believe that the absence of a "real" SA means that you have a crappy system.

What would be the "real" SA's of a Law or Accounting firm other than energy, consumable materials and toilet water? I can see it now, "I can't recommend you for certification because you haven't identified what I THINK (it doesn't matter what you think) are your SA"s. "

Next questions....

Is having a list of Significant Aspects absolutely required by the standard?

Are having environmental O&T's absolutely required by the standard?

These questions ought to start some action
:vfunny:

Using that line of thought the company Marc is discussing in the thread "ISO 14000 in Trucking" could have a hard time earning a cert if an auditor wasn't happy with the lack of SA's. I find it hard to believe that the absence of a "real" SA means that you have a crappy system.

What would be the "real" SA's of a Law or Accounting firm other than energy, consumable materials and toilet water? I can see it now, "I can't recommend you for certification because you haven't identified what I THINK (it doesn't matter what you think) are your SA"s. "

Next questions....

Is having a list of Significant Aspects absolutely required by the standard?
Are having environmental O&T's absolutely required by the standard?

These questions ought to start some action :vfunny: Your first comments are like "duh". That is like railing that judges who sit on the bench can determine your fate. And that is why a reputable registrar uses well-qualified and trained assessors to use their experience and good judgement.

As far as your last two questions, the answers are yes to both. No question, no debate.

I don't think you can get around the O & Ts Randy, it is one of those dreaded "shall" statements. However the "significant" aspects could be debated. It doesn't say you "shall" have significant aspects. If you determine that no aspects would have a significant impact then why would you have a significant aspect?
Yep, I'm sure you'll get blasted on this one. It's open to that "auditor judgement" call!!!!:eek: The first thing that comes to mind is the old public service movies in elementary school of the 60's - DUCK & COVER!!!!
:vfunny:

Jimeny cricket. If you don't have any significant aspects, what the heck are you directing your O & T's at??? If you don't have any significant aspects, why the heck do you even have an EMS??

No matter how insignificant an aspect may be,.. within the context of your EMS you must make a determination that it is at least significant enough for you to establish O&T's ! This determination is what calls it "significant".

It doesn't say you "shall" have significant aspects. If you determine that no aspects would have a significant impact then why would you have a significant aspect?
Yep, I'm sure you'll get blasted on this one. Sure, I'll do some gentle blasting.:vfunny:

If you say you don't have any SA's, what company are you comparing with? You are not supposed to compare, you're supposed to find *your* SA's. The worst ones *you* have.

/Claes

Jimeny cricket. If you don't have any significant aspects, what the heck are you directing your O & T's at??? If you don't have any significant aspects, why the heck do you even have an EMS?? You've opened up a good line of thought which I will attempt to address.

The world of business is not made up of just manufacturing facilities and large conglomorates. A majority of business (at least here in the US) is made up of Mom & Pops and other small business entities.

What "Significant" aspects would a home based business consultant have? What could a home based business consultant really do that would have the potential to significantley impact the environment? Probably NADA.

Now why have an EMS if you don't have SA's? The answer is short..$$$ (possibly) or how about just getting a warm fuzzy?

Anybody wishing to list themselves as a US Government contractor is required to specify how they will manage quality within their organization if they are awarded a contract. One of the options provided is to stipulate ISO9000 as the management mechanism. I have had to do this. Do I have a system in place? Not at this time, but if awarded a contract I'll make it happen real quick (3rd party certification is not required by the gov't).

Now wouldn't it be wise for a business wishing to do contracted environmental consulting work for the government to also be able to say they conform to an EMS, especially if the work entails implementing an EMS? Possibly.

The ISO 14001 standard was intended to be used by any type of organization regardless of their potential to do harm to the environment. Even the Sierra Club or a day care center could implement an EMS. Lord knows they don't have many SA' s(negative anyway).

O&T's don't have to be attached to SA"s. An O&T could be to use 40% recycled material in the home office, or to keep the lights off and use sunlight during the day.

I'll stop rambling here

Originally posted by Lucinda
If you don't have any significant aspects, why the heck do you even have an EMS??Because Ford says they have to do the 14001 dance... :thedeal:

...And what Marc says brings up another topic "What is a supplier?"

Would a 1 person home based consulting company wishing to do business w/Ford, GM or whoever need to dance as Marc so aptly put it? Remember there are some organizations that accept self declaration, so registration may not be mandatory.

What would be the SA's for this company? What kind of O&T's would be appropriate?

A few of us are in this position.....

My favorite two lines are: “What does the standard say?”, and “Where is the ‘shall’?”

If we read 4.3.1, we will find that a procedure is required to identify the environmental aspects. It does not say that this identification must be documented (although showing “evidence” of the identification may prove to be a bit difficult with out documentation). It also states that we need to determine which have or can have significant impacts on the environment and those aspects related to significant impacts are considered in setting environmental objectives.

4.3.3 states that we will have documented environmental objectives and targets at each relevant function and level within the organization. There is nothing that states objectives will be for significant aspects only.

Therefore, I submit that an “aspect list” is not required, where objectives and targets are. Organizations tend to overlook the “at each relevant function and level within the organization.”

within the context of your EMS you must make a determination that it is at least significant enough for you to establish O&T's !
I don't agree. Even if something tops my list, i.e. dry cell battery disposal, I don't have to say this is significant. I look at the risk analysis, cost breakdown, etc. and determine that a battery disposal box and someone to take them for disposal for the 8 batteries a week generated is all I need. Why make it significant?

Remember there are some organizations that accept self declaration
It wasn't too long ago that 14000 allowed you to self certify. Now I have to spend a good deal of money so someone can tell me what I already know - I have my bases covered! :bonk:

Because Ford says they have to do the 14001 dance...
It's not always a dance Marc. Most of the time it's a Dog & Pony Show.

I guess I should spend some time clarifying my questions and statements. I was really busy this morning...

(and just because I still have taxes to do I won't take the time to point out all those nasty significant aspects a daycare center would have Randy..I'm sure you've thought about it some already yourself)

What I meant is...why have you developed O&T's to address aspects if you did not consider them to be significant? And if you say because I had to have some O&T's in order to have this EMS which I'm required to have, then the obvious question is why don't you then label these aspects you are addressing as your significant aspects? Obviously you put them through some sort of thought process that determined you would do something about them and they floated to the top. That is what significance means, not that it is necessarily going to have a profound impact on the survival of the human race if you don't do it.

Claes said it and I agree : it is the worst of what you have no matter how slight it may be.

How many aspects could a home based business have? Gosh. What about the beer cans? :vfunny:
It is not all about manufacturing. Simple homemaking EMS's can rely on preparing baby food yourself instead of buying jars. Or carrying your own canvas grocery sacks to the store. Or refilling a thermos with water instead of using little throwaway bottles. Or using cloths to wipe up spills instead of papertowels (or at least feeding the papertowels into your fishing worm bed if you use them).

Dave,

I was told by the best EMS auditor in the world ( IMHO of course ) that an aspect list is required. Remember, it ain't just the words of the standard......!

I was told by the best EMS auditor in the world
Has the best EMS auditor in the world ever actually managed an environmental program?
I have..

How many aspects could a home based business have? Gosh. What about the beer cans? I wouldn't know much about that myself. Being a good dry Baptist and retired city cop that made his living scraping piles of goo off of streets the beer can thing wouldn't fit me.

those nasty significant aspects a daycare center would have The last time I looked pretty much everything nasty was bio-degradable and posed no risk of significant impact upon the environment..at least not as much as a big ol' pile of Texas Bull Bagles. Wahooo Hook em Horns..

Please, please, please show me where I must (shall we use the word SHALL" have significant aspects.

Oh yes.....as for the Texas remark..Graduate..Crockett High, Austin, Texas (actually shot at by Charles Whitman in '66 even)...former student Southwest Texas University, San Marcos

I've read and re-read thae standard at least a dozen times and do not find anywhere that states an aspect list is required. Nor do I find anywhere that states that i should listen to the subjective whims of some third party asuditor.

However that thought may change. Next month I'm taking the lead auditor course and I may learn that one must read between the lines to make these types of determinations. :rolleyes:

When you take your course you will find the standard the same as the one you are using now.

As for providing advice, the line between auditing and consulting can be very fine. But, if you are relating past experiences in the form of idle converstaion such as telling a story that contains material related to the subject at hand , you might possibly stay on the correct side.

Lucinda,

I always tell my clients to have a list (or matrix)! It is the best way I have found to keep track of aspects and things. If I were auditing, I would ask some detailed questions to the auditee who did not have a list. However,

I have heard auditors say that QMS requires an "approved vendor list". I have heard auditors say that management review must be in the form of a meeting.

The point I was making is that the standard does not prescribe the method to identify aspects and determine which are significant. If an auditee had a physical file with a folder for each aspect, and significant aspects marked with a red dot, I would think that could suffice.

Now about the daycare… I could think of three aspects that could be considered significant. As you mentioned, the refuse is one, electricity could be another and noise could be a third.

My home business Pepsi bottles have a deposit, so I don’t consider them. Now potato chip bags are a different story!
:vfunny:

Originally posted by Lucinda
Jimeny cricketHa! Finally got 'cha! It's Jiminy! And (family name) Cricket with a capital C! ;)

http://Elsmar.com/gif/Jiminy_Cricket-a.gif

http://www.toonopedia.com/jiminy.htm

Quite a few Walt Disney animated features have yielded ongoing characters for the company to exploit. Scamp, from Lady & the Tramp, starred in a long-running newspaper strip, as well as in comic books from the 1950s through the '70s. Mad Madame Mim, from The Sword in the Stone, became a comic book character, and is still seen occasionally in parts of Europe and Asia. Timon & Pumbaa, from The Lion King, had their own TV show. By far, the most successful of these feature spin-offs is Jiminy Cricket.

Jiminy was introduced in Disney's second feature, Pinocchio, released Feb. 23, 1940. He represented a character identified in author Carlo Collodi's original book version only as "the talking cricket", and served as Pinocchio's conscience — a role that got him righteously squashed in the book, but catapulted him to stardom in animation.

Jiminy was designed by master animator Ward Kimball at the direction of Disney himself, who thought there was something missing from the Pinocchio film as it was originally proposed. Apparently, Jiminy was it, because many commentators think he pretty much stole the movie. The Cricket's voice was provided by Cliff "Ukelele Ike" Edwards, a minor radio actor of the 1930s and '40s who is best remembered for this role.

It was rare back then for a character to appear in more than one Disney feature.<hr>Ok - I'm done now. Back to the topic!

But can I still say Geez Louise??:)
Has the best EMS auditor in the world ever actually managed an environmental program? Yep. And quality too. Cut his babyteeth on the family's hazardous waste disposal business way back in the dark ages. Degreed in environmental engineering. Was a member of the group that preceeded TC207 and then continued on to TC207. (please forgive me if my memory has failed on the correct designation..) You and he would have some great conversations.
The last time I looked pretty much everything nasty was bio-degradable and posed no risk of significant impact upon the environment.
Dave’s got this one started too, but I would want to include areas such as the kitchen and all that entails : baby food jars, milk cartons, juice boxes, food waste, dishwashing activities, rodent and insect control, etc.; and cleaning cabinet : disinfectants, air fresheners, paint storage, paper towels and baby wipes ,etc.; and playground : equipment choices and upkeep, impact absorbent materials, waterplay areas, insect control ( standing water issues, etc.) , visual impact issues, certainly noise; and without continuing down an exhaustive list let’s cut to the one that everyone thinks of in terms of daycare waste: disposable diapers.

You mentioned biodegradable. Nothing here is a biodegradable candidate; and those items that might be labeled “biodegradeable” will end up in a plastic bag buried under more trash and then covered with a layer of soil in a landfill and will never experience the air, light, and water that is needed for the degrading. Most municipalities certainly consider solid waste to be a “significant environmental impact”.

But the key here is that for an aspect to be considered significant it does not have to have a significantly adverse impact on the environment (as I understood you to mean in your comments when you dissed the daycare business as not having significant aspects). That is why orgs are allowed to design their own sig tests. It is not so they can blatantly ignore environmentally adverse aspects, but so that they can include any items that might ordinarily be considered “negligible” or “minor”. It provides a business owner a way to address what he is actually capable of doing, despite not having the obvious air and water discharge issues.

A small business with limited aspects can always look to their purchasing activities to support products that are environmentally friendly in manufacture or in disposal, or to patronize companies who are also trying to do their part. A small company with design responsibilities can design for the environment.

You ask “where is the shall” in having sig aspects. My opinion is that you have defined your significant aspects by establishing O&T’s to address them. No matter how environmentally “insignificant” the aspect may be, within the context of the EMS it has met the test of which aspects deserve attention. Hence ‘significance”. An EMS does not live without significant aspects. You might as well ask “where is the shall” in a child having a mother? By definition, a born human being had a mother.

If a company finds itself choosing not to address significant aspects that have made it through their filter (cost, time, whatever reason), but chooses instead to address other aspects which it has not defined as significant, I would say that they need to take a look at their significance test. They apparently need to broaden their criteria since the aspects they want to control (and are able to) don’t fall within the golden circle.
The point I was making is that the standard does not prescribe the method to identify aspects and determine which are significant. If an auditee had a physical file with a folder for each aspect, and significant aspects marked with a red dot, I would think that could suffice
I admit I should not have said “list”. You are absolutely correct that the aspects can be identified in multiple documents as you have pointed out, and my friend would have accepted this as well. What I meant to convey was that the aspects should be documented. A list is the easiest way, but not the only one. He’s the same auditor friend who once said that in order to “identify” something you document it. So in “identifying” the aspects……

You are absolutely correct that the aspects can be identified in multiple documents

I'm all choked up. You said I was correct:ko:

Lucinda, I was probably too focused on the "list", and your comments are valid. BTW, I posted on the "Chicken Bone" thread what some would call a sanctioned interpretation on sa and permits.

But I think I need to correct one last thing (for now). Marc indicated you spelled the name wrong. I don't think he said you couldn’t use it. (Disney might have a thing to say, however)
:biglaugh:

Oh pooh Randy, you noodle brain. Those were dave's comments that I said were absolutely correct. :)

Dave, I saw what you posted on Chicken Bone but I didn't see where it mentioned permitted activities specifically. It seemed like the focus was more on whether a company was responsible for aspects produced by another and under which it had no (or limited) control. Maybe I should look again, but real busy right this second.

Lucinda you were right on both accounts (although I wasn't going to be the one to pop Randy's balloon). The correct question has been posted (I think).

Shucks:bonk: :truce: