ISO 14001:2015 transition audit - Major NC due to the procedure and audit plan

[AliGuff]

Please help me from thinking I am going mad. We have a 14001 2015 transition audit in 3 weeks. I recently carried out an internal audit on "internal audits" for our Env advisor. (I am Quality)

I audited against the 2015 standard as that is what we are being audited against shortly. There was a major NC due to the procedure and audit plan not following the 2015 standard.

The Env Advisor has told me I should have audited against 2004 standard as that is what we are certified to at the moment.

With 9001 I was told to treat the transition audit as a recertification audit. The system should be running to the 2015 standard at least 6 months previous so there was something to audit. How can you audit a system against 2015 if you haven't be running the EMS to it?

I have told the Env Advisor this, and also his Boss so he is prepared when we fail the audit.

Can someone please confirm if I am correct?

Thanks

 

[antoine.dias]

Yes you are correct.
In fact, for a recertification you have to be able to show a complete cycle of internal audits, a management review, ... according to the standard against which you are going to be checked by the external auditor.

 

[Paul Simpson]

Please help me from thinking I am going mad. We have a 14001 2015 transition audit in 3 weeks. I recently carried out an internal audit on "internal audits" for our Env advisor. (I am Quality)

I audited against the 2015 standard as that is what we are being audited against shortly. There was a major NC due to the procedure and audit plan not following the 2015 standard.

That's an interesting 'Major' as there is no requirement for a procedure / plan to 'follow' an edition of a standard. It just has to address all the requirements (shall statements) ... and as there are very few of them ...

The Env Advisor has told me I should have audited against 2004 standard as that is what we are certified to at the moment.

In theory you should try and address both the 2004 and 2015 edition of 14001 during the audit to demonstrate current compliance to 2004 and readiness for 2015 .. in practice I'd lean towards the 2015 edition.

With 9001 I was told to treat the transition audit as a recertification audit. The system should be running to the 2015 standard at least 6 months previous so there was something to audit. How can you audit a system against 2015 if you haven't be running the EMS to it?

I have told the Env Advisor this, and also his Boss so he is prepared when we fail the audit.

Can someone please confirm if I am correct?

Thanks

The '6 months' figure is often quoted and can be a useful yardstick when you're revising a system. The important thing is to demonstrate evidence of satisfying requirements. Some requirements can be satisfied with a one off activity (say generating evidence of determining environmental aspects; others there should be evidence of consistent operation of a process for handling waste, for example.

The idea of a timetable (like 6 months) is to enable processes to bed down and that certification isn't solely based on intent.

For transition there is a bunch of evidence the system satisfies the 2004 edition, all the organisation has to demonstrate is sufficient evidence that 'new' requirements have been addressed as well.

Hope this helps.

 

[AliGuff]

Thanks for the information.

The audit procedure states the audits are undertaken against the 2004 standard.The audit plan for Jan - Dec 2017 is to the 2004 standard. There is no audit plan in place for the 2015 standard let alone any audits completed covering the new elements - Context of Organisation, Leadership, Planning etc

There has been no MRM against the 2015 standard. The Environmental Manual has not been updated.

In a previous job I have set up a 14001 system and became certified. I am not totally up to date on the 2015 standard but I have recently transitioned 9001 so I know what is expected of the first few sections.

I will be extremely surprised if there is not a major NC in the audit as we are not currently working the 2015 standard

 

[Randy]

If you've got a Transition audit to 14:2015 coming up then everything has to be in place to show conformance to 14001:2015 and not 14001:2004 so you will not be successful, no if's, and's or but's...As far as you're concerned for transitioning to 14001:2015, 14001:2004 does not exist, it's history, down the drain, gone.

I've already gone down this path during a couple audits and the clients were not happy with the results at all.

From this point forward any problems are self inflicted for a majority of organizations that are hit with them because this didn't happen overnight, it's been nearly 2.5 years in the making and procrastination won't fix anything.

Here's one very big past/present self inflicted wound....referencing ISO 14001:2004 in documents, it's not required by anything and 999 times out of a 1000 does nothing but add useless fluff.....

 

[AliGuff]

Thanks Randy. These are my thoughts also.

I joined the company in July 17, 4 weeks before the 9001 transition. Some work had been done but a lot hadn't. I managed to do a lot and luckily had a sympathetic auditor who took all circumstances into account. He knew the previous QM, who was then on contract, understood the situation and realised what work had been done. Yes we had some minors but got through it.

The 14001 is "run" by the H&S and Env advisor. He has not taken my advice . All I can do, and have done, is made his boss aware of the situation

Thanks for all the replies

 

[AndyN]

"We have a 14001 2015 transition audit in 3 weeks. I recently carried out an internal audit on "internal audits" for our Env advisor. (I am Quality)

I audited against the 2015 standard as that is what we are being audited against shortly. There was a major NC due to the procedure and audit plan not following the 2015 standard.

The Env Advisor has told me I should have audited against 2004 standard as that is what we are certified to at the moment."

IMHO you are both off track here. Paul has made a good point about the "procedure and plan not following 2015" as this isn't a requirement and, hence, cannot under any circumstances be considered a "major". Has any work been done to update the EMS to the new requirements? Did you ascertain this BEFORE you launched into the audit? A quick look at the EMS BEFORE you started to audit might have helped avoid the situation which has been created - in fact, ISO 9011 pretty much says so. If the EMS person hasn't done the work, then they can take the fall for the result of the coming CB audit...

 

[AliGuff]

I did the internal audit for the 2015 standard as I knew that was what we are being recertified to this month. There was no reason to suggest that we were still working solely to 2004.

The Env Advisor boss has spoken to him and has ascertained that no work has been undertaken on the 2015 standard, but the env advisor reckons he can get it sorted in 3 weeks and pass the 2015 audit.

Boss is making the decision whether we go ahead with the audit with the high probability of major non conformances, or cancel and give ourselves a few months to turn things around

 

[Jen Kirley]

The changes to 14001 are not as many or profound as with 9001, so the transition may need less time for environmental. Still, there is no time to lose.

Both standards require audit planning to take into consideration status, importance and results of previous audits. Risk based thinking could be apparent in these being demonstrated in the audit planning.

I agree you do need to audit to the new standards and hold a management review to include the 2015 inputs and outputs, yes including results of audits performed to the requirements of the 2015 standards. Some of the new requirements (for trended data, for example) may not be possible yet but please ensure you are operating to the new standard. I have written a lot of NCs for that, as Randy has.

 

[AliGuff]

Somehow, and I still don't know how, we have passed the transition audit, with just a few minors.

One of the minors relate the legal requirements of FGas testing. Is it correct that this should be a minor? When I have previously been through a first certification audit we were given a major for the same thing as it is a legal requirement?

The auditor seemed happy that we audited the system even though all the audits stated they were to the 2004 standard. We have not had a MRM to the new standard either, just a management briefing.

I have yet to see the report but I would have expected the audits and MRM to be picked up