Posts: 15
From:Arden, NC USA
Registered: Jan 2001

posted 09 February 2001 12:58 PM               

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We have identified 250 aspects. Is there a requirement to document ALL aspects in work instructuions where they apply; or are we just required to document those determined significant?

It seems this is left to auditor interpretation! Help!! Where can I go to get clarifaction??

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Posts: 228
From:Barstow, CA, USA
Registered: Jun 1999

posted 09 February 2001 07:39 PM               

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250 Aspects? You seem to be pretty intense.

You need to identify your aspects in some way shape or form, but specifically address those which "YOU" perceive to pose or present a "Significant Impact" on the environment and those aspects that you have control over. Remember to set your "Targets and Objectives" and be able to show "Continua; Improvement" when you are addressing Aspects and Significant Impacts.

Did you identify any Positive (+) Aspects?

My brain is fried right now...give me a little bit to come back with some better answers for you.

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Posts: 15
From:Arden, NC USA
Registered: Jan 2001

posted 12 February 2001 07:10 AM               

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Yes we do identify positive as well as negative aspects and rate all of them to determine what is significant. The ones identified as significant are tied to EMS Policy and Targets and Objectives.This is well documented.

A "consultant" made the ststement that ALL aspects had to be identified in work instructions. All I find in the standard seems to focus on the ones identified as significant.

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Posts: 4119
From:West Chester, OH, USA
Registered:

posted 12 February 2001 07:46 AM               

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You have to use your common sense. What requires documentation? Ask yourself that. Ask yourself why! Your auditor will not know. The auditor will expect you to be able to explain what you have WIs for and what you do NOT have WIs for. And the auditor will probably ask you to explain why to both do have and do not have.

Let's take soldering - I recently used that as an example in a thread here - you have someone who is soldering who was trained to Mil-Std 2000 at China Lake. Do you need a WI if your job criteria requires some type of training or certification? I doubt it. But then say you hire off the street and have some through hole soldering to do. YHour job requirement is minimal on-the-job training. You would probably want some type of instruction which addresses iron tip temp., characteristics of an 'acceptable' and 'unacceptable' joints (typically visual boundary samples), tip cleaning and other relevant operational features and accept / reject criteria.

If your registrar's auditor is telling you what should be and should not be documented in a WI (or other instruction / procedure) are, you have a very serious gap in understanding the requirements of the standard. I suggest you get some professional help.

Over documentation is very common. It takes thought and common sense to address. Over documentation is costly, confusing, sometimes insulting and detracts from the goal. I always address documentation at the start of any implementation process.

The following is from my contact at Anaren (see Elsmar.com/level2/accolades.html )

--> Subject: Results?
--> Date: Thu, 24 Jun 1999 16:29:21 -0500
--> From: XXXX
--> To: marc@Elsmar.com
-->
--> Well, as you anticipated, we "passed" with relatively few problems.
--> We had only 7 isolated non-conformities across 5 elements. Details
--> are in the attached file. The auditor said that this was a very
--> good result when compared to other registration audits he has
--> performed. All I can say is I am glad it was successful and Marty
--> said that she was happy to finally win! Once again, thanks for the
--> help. You're advice was extremely important. Especially important,
--> at least in my opinion, was your help in determining where we did
--> not need to document every last thing (by using training, etc.). I
--> think that without this input, we would have spent a lot more time
--> writing things that we did not need and wasted a lot of peoples'
--> time. We were able to get the audit done in a year while we are
--> achieving record sales and profits. Who can argue with that?

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Posts: 228
From:Barstow, CA, USA
Registered: Jun 1999

posted 12 February 2001 08:58 AM               

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All Aspects covered in the WI? Never happen.

You can have a simple list of your Aspects. You only need to emphasize those which pose a Significant Impact, and you get to choose, not the Auditor or Registrar.

Marc is correct about over documentation. Too much paper can weigh you down and create more problems like all that documentation becoming an Aspect itself.

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Posts: 38
From:Edgemont, PA, USA
Registered:

posted 14 February 2001 01:59 PM               

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The question about aspects and impacts is always what is "significant". If you have a reasonable basis for identifying what is significant then you can use those aspects.

Justification of significance can come from process hazard analyses, consequence analyses or other similar technology, but should not just be a perception.

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Posts: 19
From:Ont. Cda.
Registered: Jan 2001

posted 20 February 2001 07:33 AM               

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We first identified our aspects then evaluated to determine which are "critical".

Next determine your Criteria, eg.
a. Regulatory Requirements
b. Financial
c. Business Plan
d. Potential Effect on Environment
e. Stakehold Opinions

Then use a rating system, example 1 -3, 1=Low, 2=Medium, 3=High.

Example. Regulatory Requirements
Low = No existing regulations
Medium = Regulations exist. Minimal risk of violations or cost
High = Regulations exist. Possibility of violations or costs.

We did this for all our aspects for each of the criteria. Totalled the columns then ranked them accordingly. From 50 identified aspects 11 aspects where recognized as critical.

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Posts: 228
From:Barstow, CA, USA
Registered: Jun 1999

posted 20 February 2001 09:21 AM               

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The action Cheryl described seems to be the norm with variations. The auditee has the right to determine how it analyzes its Aspects and makes the decision on which ones are significant. You can write all your Aspects on chicken bones, toss them in the air and whichever ones land face up can be the determining factor. The decision belongs to the Auditee, and as long as the process is consistant and the required subsequent steps are followed you cannot (should not) be faulted.

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