Communication of environmental policy "for persons working on its behalf" (4.4.2)

[QMarc]

Hi covers,

normal tools for communication of the environmental aspects or policy "for persons working on its behalf" (4.4.2) are information sheets or internet publications.

Do you have any other (more innovative) suggestions to manage these requirements?

Thanks
QMarc

P.S. It is a question arising from a german forum and there were only standard answers

 

[Randy]

The policy can be included in contract statements, as advertisements in periodicals, product sales materials and newspapers, and others.

 

[tarheels4 - 2007]

Communication Of ISO 14001 Registration

Suppose a company wants to communicate to customers and potential customers that it is ISO 14001 registered and produces and distributes brochures that advertise its products and the fact that the organization is ISO 14001 before they are registered by a 3rd party.

Then suppose the 3rd party auditor comes along and discovers the brouchure during the registration audit and there is evidence that the brochure has been distributed to stakeholders.

What would a reasonable auditor do??

 

[Randy]

10 lashes with a wet noodle.

Good question. I'm actually in our corporate office today and I'll ask about this, I've never had it happen or even thought about it.

 

[Jim Wynne]

Suppose a company wants to communicate to customers and potential customers that it is ISO 14001 registered and produces and distributes brochures that advertise its products and the fact that the organization is ISO 14001 before they are registered by a 3rd party.

Then suppose the 3rd party auditor comes along and discovers the brouchure during the registration audit and there is evidence that the brochure has been distributed to stakeholders.

What would a reasonable auditor do??

It's an interesting question, but the original question was about communicating the policy, not advertising registration status. In the case you propose, there's obviously been some false advertising going on, but if the registrar isn't mentioned by name, and protected language/symbols aren't used, it should be of no concern to the auditor so long as the company's policy is compliant and has been adequately communicated.

 

[tarheels4 - 2007]

I have had this come up. The guidance below touches on the the subject. To me it is saying that the registrar's procedures need to address what they would do in the above case.

I am interested to see what Randy comes up with.

IAF Guidance on the Application of ISO/IEC Guide 66
IAF Guidance to Clause 5.7. (G.5.7.1. to G.5.7.5.)

"G.5.7.1. The certification/registration body should have documented procedures for the use of its mark, and for the procedures it is to follow in case of misuse, including false claims as to certification/registration and false use of certification/registration body marks."

 

[Jim Wynne]

I have had this come up. The guidance below touches on the the subject. To me it is saying that the registrar's procedures need to address what they would do in the above case.

I am interested to see what Randy comes up with.

IAF Guidance on the Application of ISO/IEC Guide 66
IAF Guidance to Clause 5.7. (G.5.7.1. to G.5.7.5.)

"G.5.7.1. The certification/registration body should have documented procedures for the use of its mark, and for the procedures it is to follow in case of misuse, including false claims as to certification/registration and false use of certification/registration body marks."

I'm also interested in seeing what Randy says (as I'm always interested in what Randy says ). I think the language you quote is (typically) ambiguous, and seems to pertain to claims that include use of protected marks and references, and allows for the certification body to have a procedure that says, "don't worry about it."

 

[tarheels4 - 2007]

and allows for the certification body to have a procedure that says, "don't worry about it."

Yep

 

[Helmut Jilling]

Hi covers,

normal tools for communication of the environmental aspects or policy "for persons working on its behalf" (4.4.2) are information sheets or internet publications.

Do you have any other (more innovative) suggestions to manage these requirements?

Thanks
QMarc

P.S. It is a question arising from a german forum and there were only standard answers

In getting back to the original question... This will probably raise some debate, but this is an important question.

Cl 4.2.f says an organization's policy has to be communicated. We need to consider what is the purpose for this requirement.

Cl 4.2 says an organization's policy has to include a commitment to prevention of pollution, obeying legal requirements, framework for setting objectives and targets. The policy frames the expectations an organization has that its employees will carry themselves in such a way as to meet the organization's "policies."

If Cl 4.2.f says the policy has to be communicated to other people working on its behalf, what would be the reason for this requirement? Because these other people haven't gone through the company's training and EMS system implementation, but somehow, we still want them to carry themselves in such a way as to meet the organization's "policies" to be environmentally aware and prevent pollution, etc.

So, however we communicate it, this communication needs to be likely to result in subcontractors understanding and doing the right things as well. Otherwise, it is not effective, and adds no value.

This intent is further reinforced in 4.4.2 when it says these other persons are competent, etc... We're trying to prevent pollution caused by employees or nonemployees who are doing things on our behalf.

We need to communicate our expectations, and whatever else is needed to ensure they are likely to perform according to our expectations. We also want to keep it reasonably brief, and easy to understand, so it works but does not get in the way of the job we asked them to perform. This is actually a challenging requirement, not just a stack of flyers lying in the lobby.

Isn't the reason to help ensure that the subcontractor also performs in a manner consistent with the organization's policy?

 

[QMarc]

Thats what I was talking about

@hjilling

This is exactly the reason for my question.
My interpretation of 14K is to get the stame standard for contractors as for the own company.
Is it still enough to communicate the policy, targets and objectives?

In my opinion no. I think you should also have a look to the persons working on behalf and check the level of conformity with legal requirements for example.

Isn´t that also the idea of 9001 to evaluate suppliers quality standard with supplier audits?

QMarc