Section 4.3.1 - Limiting an EMS scope to facilities only

Tyranna

Involved In Discussions
Greetings!

Per 4.3.1 - (which refers to 4.1 - General Requirements/Scope The org. shall define and document the scope of its environmental management system)

The org. shall establish, implement and maintain a procedure(s)
a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and

which also ties to 4.2 Environmental policy

Top management shall define the org's enviro policy and ensure that, within the defined scope of it's environmental management system, it:

a) is appropriate to the nature, scale and environmental impacts of its activities, products and services,


Taking into account that all of these requirements are tied together by scope -

Is it possible to limit a scope to include ONLY the facilities and not the product and services that are made/offered by the organization?

Is it possible to define the scope to a facility based EMS system and not include the products or services that the facility produces?

"Facilities" refers to building and grounds and internal spaces and excludes end product.

This should be interesting as the 14001 document does say: Organization shall define and document the scope.

Thank you for your insight!
 

insect warfare

QA=Question Authority
Trusted Information Resource
Is it possible to limit a scope to include ONLY the facilities and not the product and services that are made/offered by the organization?

Yes, unless the product or service itself has the potential to create significant environmental impacts.

Is it possible to define the scope to a facility based EMS system and not include the products or services that the facility produces?

Again, yes, unless the product or service itself has the potential to create significant environmental impacts. An environmental gap analysis should indicate to you if your scope is appropriate.

And while the organization has latitude to define EMS scope, it is not total freedom - the CB can deny your certification in extreme scenarios (for example, you claim conformity to 14K while not taking consideration of the fact that you are manufacturing ammonia in the front while making bleach in the back, since if the two substances were to ever come into contact, it could produce very noxious gases which could be harmful to both flora and fauna).

Brian :rolleyes:
 

Tyranna

Involved In Discussions
Hi,

Thank you for your response.

:thanx:

During an audit, if products and services are not within the scope, would the Manager of the system have to show that the product and service were evaluated and determined to not be a hazard?

I promise - my last question on the topic!

thank you again!
 

insect warfare

QA=Question Authority
Trusted Information Resource
Tyranna,
Let me re-clarify my answers more suitably (I should slap myself for jumping the gun on my initial response and getting it wrong)....

Is it possible to limit a scope to include ONLY the facilities and not the product and services that are made/offered by the organization?

Is it possible to define the scope to a facility based EMS system and not include the products or services that the facility produces?

NO, according to 4.3.1 (a) you must include your activities, products and services - even if they are not determined later to have significant impacts. If you do not include activities, products and services in your scope, you will not be likely to evaluate them in order to know if they will have significant impacts or not, plus you will not be in conformance with ISO 14001 if you exclude them. Annex A.1 of ISO 14001 (informative only) also backs this up:

An organization has the freedom and flexibility to define its boundaries and may choose to implement this International Standard with respect to the entire organization or to specific operating units of the organization. The organization should define and document the scope of its environmental management system. Defining the scope is intended to clarify the boundaries of the organization to which the environmental management system will apply, especially if the organization is a part of a larger organization at a given location. Once the scope is defined, all activities, products and services of the organization within that scope need to be included in the environmental management system.

During an audit, if products and services are not within the scope, would the Manager of the system have to show that the product and service were evaluated and determined to not be a hazard significant?

Based on the information given above, YES....since your boundaries consists of those facilities, so should it encompass the activities performed and the products made and services utilized in those facilities.

Brian :rolleyes:
 
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