Informational Companies with No SIGNIFICANT Environmental Aspects - ISO 14001

[Paul Simpson]

Re: ISO 14001 with No SIGNIFICANT Environmental Aspects - Small Service Company

the coI shall rephrase slightly ;

Also while there are myriad indirect aspects for any company, isn't the focus supposed to be on those withinmpanies ability to change/effect/control/influence.

Absolutely! You need to do what you can do. But for organisations like yours what you can do sometimes is influence some of the dinosaurs outside your organisation.

I remember having this sort of discussion with my trainer when I went on the auditing course - largely because our company has very few environmental impacts that we aren't already doing the best we can to mitigate. And while technology etc changes - it doesn't change that quickly in certain areas.

To illustrate;

We are a small IT services company - what we do hasn't changed significantly for quite a few years - all the paper is shredded and recycled, as in fact is all our waste (recycled not shredded, that would be messy).

Now this was the comment that made me giggle! Many would put the 'check in the box' by doing something insignificant - whereas you are questioning the approach - good for you.

May I just say at this point I do not have a solution for you but I admire your problem!

We make extended use of remote technologies and that type of thing. All our hardware is as low-power/low-emission as we can get it.

When I do an audit on the environmental side I find that, just like last time, we are basically at the best practice level - so what do we do to show continual improvement?

Are you? Seriously. The whole process relies on you knowing what you do (Aspects) and controlling them and improving. Get someone else in to have a look - Envirowise are cheap (even free) and get some good results. But do take a long hard look at yourself. Whenever I do that I find plenty of opportunites to improve.

While I can see that there might be some sort of revolutionary technology appear between one accreditation visit and the next, there generally isn't.

Is it a case of constantly trying to tweak our procedures to try and creep upward on some metric?


That said - I have just thought of one way we could improve which is move from the dead-tree style of QMS/EMS system to an electronic one, but what do I do next year to improve? Use txtspeak to save characters?

Regards
T.
NB: The txtspeak thing is in no way to be regarded as a serious suggestion.

Seriously? :mg: I took you at your word!:mg: I'd just like to say that I found your contribution stimulating and refreshing. I have spent too long auditing companies that just want to comply without understanding the spirit of the requirements. Your question is a breath of fresh air!

 

[Sidney Vianna]

Re: ISO 14001 with No SIGNIFICANT Environmental Aspects - Small Service Company

If they wanted to register each location separately, they would have to have their own significant aspects then, correct?

Correct.

 

[Helmut Jilling]

Re: ISO 14001 with No SIGNIFICANT Environmental Aspects - Small Service Company

A small office activity is part of a large international company and is interested in getting added to the multi-site certificate. They follow the corporate procedure for aspects and impacts and determine that none of their aspects meet the criteria for significance as set by the corporate procedure (miniscule impacts when compared to the large corporate manufacturing sites). Would a registrar still require the small office activity to have a significant impact before recommending them to be added to the multi-site cert? Looking for some guidance - appreciate any insight provided.

The following answer is an official clarification from:

U.S. Technical Advisory Group to ISO/Technical Committee 207 ​

Clarification of Intent of ISO 14001:2004​

(The copy I have was downloaded 6-2007)

04-03.A1

Question
Is it permissible for a small organization to declare that they have no Significant Aspects and still be conformant to the ISO 14001 standard?

Answer
Although there is no explicit requirement in ISO 14001 that an organization will identify one or more significant environmental aspects, there is an underlying assumption that the organization will do so. The intent of the requirement to determine those aspects that an organization considers significant is to enable the organization to focus attention and resources on its most important environmental aspects, recognizing that not all aspects require or deserve the same degree of management. ISO 14001 does not define “significance” nor does it identify any external or absolute standard for what will be considered significant. Significance is intended to be a relative term. What is significant for one organization may not be for another, and what an organization considers a significant aspect may change over time. The use of ‘significance’ in ISO 14001 was intended to be an aid in managing a range of environmental aspects.

There is no special category of requirements in ISO 14001 for “small” organizations. The requirements for an ISO 14001 EMS, including those regarding significant aspects, are intended to apply to “…all types and sizes of organizations…”

 

[Sidney Vianna]

I fail to see the relevance of this "official interpretation" to the scenario at hand.

There is a big difference between a stand alone small operation versus a small remote office, part of a large manufacturing conglomerate, which is the case at hand.

This interpretation is non applicable to the scenario offered.

 

[Helmut Jilling]

I fail to see the relevance of this "official interpretation" to the scenario at hand.

There is a big difference between a stand alone small operation versus a small remote office, part of a large manufacturing conglomerate, which is the case at hand.

This interpretation is non applicable to the scenario offered.

Well...I thought it would add some insight that the expectation of the writers was that certified sites should identify significant aspects because that is the point of the program. And, contrary to your assertion that it is not relevant to small sites, it specifically stated they did not exclude small sized sites, saying ISO makes no such distinction:

There is no special category of requirements in ISO 14001 for “small” organizations. The requirements for an ISO 14001 EMS, including those regarding significant aspects, are intended to apply to “…all types and sizes of organizations…”

I think they stated their intent pretty clearly. I frequently agree with your perspective. 'Fraid I'll have to take the TAG Group's opinion over yours this time...

If it is a multi-site cert, perhaps the small office should take their cue from the Corp office and align with their defined significant aspects. If they are not applicable, there are some good ideas expressed in this thread about looking outside the small group.

 

[Sidney Vianna]

If it is a multi-site cert, perhaps the small office should take their cue from the Corp office and align with their defined significant aspects. If they are not applicable, there are some good ideas expressed in this thread about looking outside the small group.

What do you mean by IF? The scenario we are debating was CLEARLY laid out at

A small office activity is part of a large international company and is interested in getting added to the multi-site certificate. They follow the corporate procedure for aspects and impacts and determine that none of their aspects meet the criteria for significance as set by the corporate procedure (miniscule impacts when compared to the large corporate manufacturing sites).

That is exactly why the "official interpretation" does not apply to this scenario. Much more relevant to the issue at hand is ANAB's Accreditation Rule #13. Significant Environmental Aspects and Impacts which states

An organization must identify the environmental aspects and impacts that have a higher value, significance, or importance, and use these resultant aspects and impacts to appropriately address the requirements of the standard for objectives and targets, personnel training and awareness, communication, operational controls, and monitoring and measurement (as evidenced in procedures or processes). Unless the organization has done this, it cannot be certified for conformance to ISO 14001 or RC14001 because its system for determination of significance is not effective.

However, this AR does not apply to the scenario at hand, either. The "small office" is not a stand alone organization, seeking independent certification.

Can you imagine if you had a large petrochemical operation, who wants to include a remote 2-man sales office in their scope of EMS certification? Would you expect the sales office to come up with (totally irrelevant in the context of this organization) artificial significant aspects, to be certified? It would be ludicrous.

Just like any management system standard requires meaningful application, so does any interpretation, rule, etc.

 

[Helmut Jilling]

What do you mean by IF? The scenario we are debating was CLEARLY laid out at That is exactly why the "official interpretation" does not apply to this scenario. Much more relevant to the issue at hand is ANAB's Accreditation Rule #13. Significant Environmental Aspects and Impacts which states However, this AR does not apply to the scenario at hand, either. The "small office" is not a stand alone organization, seeking independent certification.

Can you imagine if you had a large petrochemical operation, who wants to include a remote 2-man sales office in their scope of EMS certification? Would you expect the sales office to come up with (totally irrelevant in the context of this organization) artificial significant aspects, to be certified? It would be ludicrous.

Just like any management system standard requires meaningful application, so does any interpretation, rule, etc.

I am comfortable with both quoted statements. The OP asked whether they need to have significant aspects. Based on both quoted statements, I think the correct ISO answer is the same. In fact, the end of the section you quoted would appear to be saying the same thing I stated. They should seek to identify significant aspects suitable for their activities. I would be comfortable with their choice whether based on the mother ship's selections or on their own unique activities.

The purpose for my post is we cannot simply state that it does not apply when the TAG writers clearly state they make no distinction between small and large organizations. I am not going to parse their brief "Clarification of Intent," nor the quote you shared. They both support the same conclusion. I can only express my views, as do you. But, I think mine are of equal merit, sir.

 

[Sidney Vianna]

The purpose for my post is we cannot simply state that it does not apply when the TAG writers clearly state they make no distinction between small and large organizations.

Apparently you fail to discern the difference between a stand alone organization from a remote office, part of a large organization. The first is responsible for a full EMS implementation. The second will only necessitate to comply with parts of an EMS and, very likely, will have no significant aspects, based on the criteria defined by the organization. There is a VERY CLEAR distinction between the two.

 

[Helmut Jilling]

Apparently you fail to discern the difference between a stand alone organization from a remote office, part of a large organization. The first is responsible for a full EMS implementation. The second will only necessitate to comply with parts of an EMS and, very likely, will have no significant aspects, based on the criteria defined by the organization. There is a VERY CLEAR distinction between the two.

I guess we will have to choose to disagree. ISO does not definitively state that every organization, office, multi site, etc. shall identify significant aspects, But, in two quoted statements both you and I shared, it seems to suggest they at least lean in that direction.

In your post #1,

But is significant a relative or absolute term in the context of ISO 14001? Obviously the impact of the example above is negligible, compared to the ones resulting form a large steel mill or petrochemical plant.

One could also ask what is the point of a small organization implementing an EMS/ISO 14001?

But what say you? Would an EMS with no identified SIGNIFICANT aspect be compliant with ISO 14001?

...you asked if no identified significant aspects would be compliant. You asked what we thought. I stated that I believe ISO intends for each organization to identify significant aspects. The quote you shared specifically agrees.

Why are you upset with me for agreeing with what the ISO statements seem to be saying? They did not exclude small or remote. They did not specifically include them. Are you somewhere at a higher, more elevated status of interpretation than the rest of us experienced practitioners? Did I miss your place on the ISO org charts of sanctioned interpreters?

Geez, Sidney! I think somewhere in my last 12 years and 1200 audits I might have developed at least a little bit of experience, and maybe even figured out what a remote office was!

I expressed my opinion, as the post requested. If you don't want to agree, that's your prerogative. This forum is to try to find reasoned opinions, not put people down...so let's play nice...I'm done with this thread....

 

[Sidney Vianna]

I am sorry you feel easily offended when a difference of opinion is expressed. What we are discussing now is not the original question, but answers to a question from post #78 of this thread.

The poster asked a clear question and I offered my advice. Your position opposes mine. So I argued my case. That is all.