CB auditor questioning procedure for Identification of Aspects and Impacts?

[Randy]

Re: CB auditor questioning procedure for identification of aspects / impacts?

This stuff is from ANAB Accreditation Rule 13...you guys tell me what "sound" means. Also tell me what the other stuff means because apparently somebody is a bit out of plumb here.

A CB is expected to evaluate the organization’s process for identifying aspects and determining their significance (G.5.3.17- b and G5.3.21) to ensure it is sound and adhered to.

Based on the preceding, an organization is expected to identify its environmental aspects and impacts, and, through an evaluation process it defines for itself, determine those that are significant. Neither ISO14001 nor IAF Guidance defines “significance” or identifies any external or absolute external standard that does so. What is significant for one organization may not be significant for another, and what an organization considers a significant aspect may change over time. There is no absolute measure of significance; rather, significance is internal to the relative importance of aspects as defined by the organization.

 

[Sidney Vianna]

Re: CB auditor questioning procedure for identification of aspects / impacts?

sound 2 (sound)
adj. sound·er, sound·est
1. Free from defect, decay, or damage; in good condition.
2. Free from disease or injury. See Synonyms at healthy.
3. Having a firm basis; unshakable: a sound foundation.

4. Financially secure or safe: a sound economy.

5. a. Based on valid reasoning: a sound observation. See Synonyms at valid.​

b. Free from logical flaws: sound reasoning.​

c. Logic Of or relating to an argument in which all the premises are true and the conclusion follows from the premises.​

6. Thorough; complete: a sound flogging.
7. Deep and unbroken; undisturbed: a sound sleep.
8. Free from moral defect; upright.
9. Worthy of confidence; trustworthy.
10. Marked by or showing common sense and good judgment; levelheaded: a sound approach to the problem.
11. Compatible with an accepted point of view; conservative.
12. Law Legally valid.

 

[Sidney Vianna]

Re: CB auditor questioning procedure for identification of aspects / impacts?

What part of the following is so hard to understand?

G.5.3.21. Recording and evaluation of environmental aspects and control of those deemed to be significant
(a) In order to provide confidence that organizations are consistent in establishing and maintaining procedures for the identification, examination and evaluation of environmental aspects and their associated impacts, certification/registration bodies’ procedures should reflect the following factors:​

• it is for the organization to define the criteria by which environmental aspects and their associated impacts are identified as significant, and to develop (a) procedure(s) for doing this;

• it is for the certification/registration body to assess that the procedure(s) by which the organization determines which environmental aspects and their associated impacts are significant is sound and adhered to;

• the certification/registration body should identify to the organization for its action any inconsistencies between the organization’s policy, objectives and targets and its procedure(s) or the results of their application.


(b) The certification/registration body should establish whether the procedures employed in the analysis of significance are sound and properly implemented. It shall verify that an environmental aspect or associated impact which is identified as being significant is managed within the system.​

 

[joshua_sx1]

Re: CB auditor questioning procedure for identification of aspects / impacts?

I’m an auditor… and I’m being audited also from time to time… even the main objective of the standards i.e. ISO is to standardize everything regarding quality, health, safety and/or environment management system, there will always have different “perceptions”, “ideas” and “point-of-views” from one auditor to another auditor… (human factors, we can say)…

I guess, one thing I’ve learned from this job is to respect one another point-of-view… he is your auditor… although, it doesn’t meant that he will always have right, but the fact that he is the one auditing you, he is in the position to be right for asking you or verifying an audit evidence…

Auditing should be a two-way information task… he audited your organization… and reported whatever findings he taught would be beneficial for your improvement… so let him do his job…

Now, the other side of the "auditing", is your part – as an auditee… this is where you can agree or disagree to the auditor’s findings… you can use this privilege to highlight your disagreement...

Regarding your question if a CB auditor has a right to question your procedure for determining environmental aspects / impacts… the answer is “yes”...

And how far he could go in… as long as you don’t satisfy the requirement of the standard (as per his point-of-view)...

 

[Randy]

Re: CB auditor questioning procedure for identification of aspects / impacts?

Ya know you guys may be on to something here. It might actually be best that organizations instead of identifying criteria for determining significance based on what is important and relevant to them, employ legal teams, scientific whizzo's and massively nutcase treehuggers so that the process of determining significance can pass legal overview, environmental science critique and sensitive person warm fuzzy's.

Golly gosh darn I must be taking that outlandish stuff about objectivity and open-mindedness too far. Oh well,lets's just toss that from 19011 as well because it has to be incorrect.

 

[Sidney Vianna]

Re: CB auditor questioning procedure for identification of aspects / impacts?

Golly gosh darn I must be taking that outlandish stuff about objectivity and open-mindedness too far. Oh well,lets's just toss that from 19011 as well because it has to be incorrect.

There is nothing in ISO 19011 which contradicts the IAF Guidance document. I think you should listen to Paul's advice and run this by your employer's technical group, and report accordingly. I doubt they would willfully state that an EMS Lead Auditor can disregard the IAF document and associated requirements.

According to your public profile, your opinions are yours only and do not reflect necessarily your employers opinion. But you can not dissociate you from your employer. At the end of the day, the people who attend your courses or get certified via an audit you lead, want to make sure you position represents the position of the leading CB/Training provider you work for.

So, either

a) your position reflects your employer's stance on this subject and me, Paul, Helmut and a few other shy lurkers would be surprised with that position, but would give you credit for defending it forcefully. Or,

b) your opinion does not reflect your employer's stance and you should re-think your approach.

Respectfully submitted.

 

[armani]

Re: CB auditor questioning procedure for identification of aspects / impacts?

OK, I see this thing has gone too far ..... be reasonable, all of u!
I want to submit to u a little question: if an organisation commitment is for observing legal requirements & reduce / eliminate polution, in establishing criteria (yes, I'm back to initial subject!!) woldn't these be mandatory, in support of my commitment? If they are not, the above commitment is....wind blowing talk!

 

[joshua_sx1]

Re: CB auditor questioning procedure for identification of aspects / impacts?

...of course, it will be mandatory on your part to comply to the requirements since your organization is the one who committed on it…

 

[armani]

Re: CB auditor questioning procedure for identification of aspects / impacts?

And...read this... (talking 'bout the wolf)

http://ec.europa.eu/environment/emas/pdf/guidance/guidance06_en.pdf

Something intrigues me: how can an interpretation of a guide bould be applied, if the guide is not valid anymore - Guide 66 (even if that interpretation wasn't replaced)?? So the object of interpretation doesn't exist anymore...

 

[Paul Simpson]

Re: CB auditor questioning procedure for identification of aspects / impacts?

I’m an auditor… and I’m being audited also from time to time… even the main objective of the standards i.e. ISO is to standardize everything regarding quality, health, safety and/or environment management system, there will always have different “perceptions”, “ideas” and “point-of-views” from one auditor to another auditor… (human factors, we can say)…

With management systems standards like the ones for areas you mentioned the aim is not to standardize process or outputs but simply requirements:

• So for quality the heart is customer requirements - 9001 requires that you have processes in place to identify these and make sure you are able to satisfy them
• For Environment the key is identifying aspects and impacts - so for 14001 you have to have a process to identify aspects, evaluate significnance and manage the significant ones
• As for health & safety the key is hazards and risks - so 18001 requires you have processes to identify those hazards, assess and control the risks

Now if you are a small organization dealing with simple customers your customer requirements, environmental aspects and health & safety risks are going to be very different from a Multi Million Global corporation. There will be very little standardization between the two organizations and systems.

I guess, one thing I’ve learned from this job is to respect one another point-of-view… he is your auditor… although, it doesn’t meant that he will always have right, but the fact that he is the one auditing you, he is in the position to be right for asking you or verifying an audit evidence…

I will always respect the right of any to have another point of view from mine - I won't just accept it, however.

There is a lot of misinformation spread about quality, environment, health & safety, management systems, you name it.

I see my life's work as challenging some of the opinions where I see no basis in fact. I am happy for any challenge, too.

Not that I have to invite them!

Auditing should be a two-way information task… he audited your organization… and reported whatever findings he taught would be beneficial for your improvement… so let him do his job…

Again I beg to disagree. An auditor should audit your system looking for compliance but should not hesitate to raise a finding if your system does not meet the standard. If there are opportunities for improvement they can raise these as non mandatory findings to be dealt with if your organization sees the benefit.

Now, the other side of the "auditing", is your part – as an auditee… this is where you can agree or disagree to the auditor’s findings… you can use this privilege to highlight your disagreement...

Agree!

Regarding your question if a CB auditor has a right to question your procedure for determining environmental aspects / impacts… the answer is “yes”...

Agree! and if they identify a nonconfomrity with requirements of 14001 they should write it up!

And how far he could go in… as long as you don’t satisfy the requirement of the standard (as per his point-of-view)...

Agree - apart from the bit about "as per his point-of-view" Point of view has no place in nonconformities.

• There is a requirement
• There is evidence the requirement is not met
• The report is written up listing the above two points