ISO 14001 Internal Compliance Audit - 5.2 "...other identified requirements to..."

[Karen-Dawn]

Hello All,

Has anyone done their internal 14001 compliance evaluation (audit in my books) as mandated by the 2004 version? The first part of 5.2 is easy - legal compliance. I am concerned with the second paragraph,"other identified requirements to which it has subscribed". Any examples or check lists used to do this? I am wondering if they mean just an internal audit to the standard and our own internal procedures and if so, how is this different from our regular internal audits, or based on 5.5 is it just how I define it in our audits?
Any thoughts or insight is appreciated.

[Randy]

How about against corporate requirements, industry specific requirements or any other requirement (not related to legal requirements) that you must meet? Remember, this only concerns those requirements that are related to environmental stuff.

One immediate "other" requirement is ISO 14001:2004. Evidence of this evaluation is your internal audit and the management review, and it may possibly be the only one you have.

[Dr. L. Ramakrishnan]

Hi,

ISO-14001 (2004) Section 4.3.2 requires that the organization identifies and has access to "legal" and "other requirements" to which it subscribes. If you have already established an Environmental Management System according to ISO-14001 you would have identified these other requirements (e.g. industry guidelines, corporate standards, customer requirements, labelling and other volantary requirements, "covenants" with local authorities etc. related to environmental aspects of your activities, products and services). Under Section 4.5.2, the organization is required to evaluate compliance with respect to these OTHER REQUIREMENTS "identified" and "accessed" as per Section 4.3.2.

With best wishes,

Ramakrishnan

[Karen-Dawn]

Thanks Guys,

We have had our system and registration for over five years now and regularly audit both legal and other requirements. I guess with the new 2004 rev though my external auditors threw me for a loop when they reviewed one audit called environmental and safety compliance and said they could wait until next year when I met the second part of the requirement for evaluating compliance...I think they are getting hung up on the section that says if a company wishes to combine audits the intent and scope should be clearly defined...with the exception of the E&S compliance audit our scopes are generally defined as management system audits and hopefully that is all I have to change.