Informational Companies with No SIGNIFICANT Environmental Aspects - ISO 14001

[Helmut Jilling]

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.

The post from #78 asked about being added to a multi-site cert:

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.

They did not ask about being a remote site, you introduced that angle. They asked about being added to a multi-site. If they are a "site," I think that ISO expressed their views in the 2 quotes you and I shared. I agree if they are listed as a remote support location, their is more room to discuss. In either case, the requirement is not explicit, so we can only debate what is best and suitable, which would have to be determined by their own CB.

In either case, I still suggest the intent of ISO is more than 50% toward the side of seeking significant aspects.

PS: I am only "easily offended" when I perceive a distinct dismissiveness or arrogance in tone. I think my experience and expertise is well established, as is your own. Let's not be dismissiveness, especially when you did not present anything from ISO that specifically supported your premise. It is apparently a grey area, and will remain the prerogative of the respective CB to decide based on the facts. Enjoy the weekend....

 

[Sidney Vianna]

They did not ask about being a remote site, you introduced that angle.

Would it make sense to add an office that is already part of the site(s) certified? So, the only plausible conclusion is that this small office is away from the certified locations.

They asked about being added to a multi-site. If they are a "site," I think that ISO expressed their views in the 2 quotes you and I shared.

ISO has not expressed anything. The document you referred to is a position paper from the US TAG to the ISO TC 207. The one that I linked to, comes from ANAB. Neither one expresses a formal position from ISO.

I agree if they are listed as a remote support location, their is more room to discuss. In either case, the requirement is not explicit, so we can only debate what is best and suitable, which would have to be determined by their own CB.

In either case, I still suggest the intent of ISO is more than 50% toward the side of seeking significant aspects.

So, in the example that I offered in a previous post

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.

You infer that the sales office WOULD MANDATORILY have to identify significant aspects to be properly managed, together with all the real significant aspects of the petrochemical plant, just because the sales office is being added to the certificate? To me, that position is unjustifiable.

Mandating that the sales office MUST identify significant aspects in the context of an EMS for a petrochemical operation is totally non-value added. Because significance is a relative issue in the context of the organization, the system, the community and the environment surrounding the envelope of the system at hand.

Note that, according to the OP, the office in question did evaluate their operation vis a vis the criteria established by the organization, for significance determination, and, still according to the poster, NONE of the aspects/impacts were found to be significant. But your position seems to force them to revise their criteria so at least one of the aspects/impacts would be deemed significant.

If I were in charge of that EMS, I would be filing a strongly worded appeal with the CB for that position. It does not make sense, the standard (ISO 14001:2004) does not require it, neither does any interpretation, position paper, accreditation rule, etc.

Sorry in advance for being passionate about my position. But I believe it to be paramount we keep business perspective and common sense, when applying standards to business enterprises.

 

[Helmut Jilling]

The document you referred to is a position paper from the US TAG to the ISO TC 207. The one that I linked to, comes from ANAB.

....You infer that the sales office WOULD MANDATORILY have to identify significant aspects to be properly managed, together with all the real significant aspects of the petrochemical plant, just because the sales office is being added to the certificate? To me, that position is unjustifiable.

Mandating that the sales office MUST identify significant aspects in the context of an EMS for a petrochemical operation is totally non-value added. Because significance is a relative issue in the context of the organization, the system, the community and the environment surrounding the envelope of the system at hand.

Look, I don't write this stuff, I just try to understand, just like you and everyone else. When the standard is not clear, it helps to apply common sense, and it also helps to ask if the writers wrote anything else that clarifies their intent.

Common sense suggests compared to a big petrochemical plant, a small office is a drop in the bucket. But, the TAG group also said they really did not intend any distinction between big and small. Everyone can (and should) try to help improve things.

I did not "mandate" anything. I merely shared their point of view as being interesting and worthy of consideration. Perhaps, even small offices can improve their aspects, or as I like to call it, their environmental footprint. In a reasonable, logical, beneficial manner. Even if it is just saving a few trees.

I was simply trying to share a point of view. Look for the good in everything...

 

[Sidney Vianna]

But, the TAG group also said they really did not intend any distinction between big and small.

That is correct. The key thing to remember here is the fact that this office location IS PART of a large organization and is being added to the certificate via a scope extension activity.

Had this office been part of the original certification process, they would have been responsible for ZERO significant aspects, according to the criteria established by the organization. That should not change just because they are being added to the certificate, at a later date.

 

[aerospaced]

Thank you very much for your discussion of this issue. I have gotten a lot of useful information from it - it almost sounds like the discussion I am having with the registrar. The registrar has indicated that every site has to have at least one significant impact. My response to the registrar is that if the remote sales office identifies a significant impact it will not be in compliance with the corporate procedure. I explained to the registrar that the corporation does not have unlimited resources and that it has focused it resources on those aspects that will have the largest impact (most significant). The corporate procedure is very clear on how aspects are to be ranked for significance. The registrar is sticking to this rule that every site has to have a significant impact and IMHO is not taking a big picture view (corporate) even though there is a multi-site cert in place. Ironic since the registrar does insist that we follow corporate procedures.

 

[bobdoering]

I explained to the registrar that the corporation does not have unlimited resources and that it has focused it resources on those aspects that will have the largest impact (most significant)....The registrar is sticking to this rule that every site has to have a significant impact...

It is really sad when the interpretation of the standard has you staring at your wastebasket trying to come up with a continuous improvement plan for your effluent - even if it was the only site. Seems like poeple don't look at the resources wasted saving resources. It is amlost like your compliance to ISO14001 is your most significant impact!

 

[Helmut Jilling]

It is really sad when the interpretation of the standard has you staring at your wastebasket trying to come up with a continuous improvement plan for your effluent - even if it was the only site. Seems like poeple don't look at the resources wasted saving resources. It is amlost like your compliance to ISO14001 is your most significant impact!

Oh c'mon... Every company and every household has an impact on the planet. Even those that aren't pouring chemicals into streams or smokestacks of soot into the air, have many opportunities to improve their environmental impact. Millions of companies and a billion plus households in the world...If we all looked for little, practical, cost-effective ways to improve the environmental footprint, it would have massive beneficial benefits. And, it would render these massive, wasteful governmental initiatives unnecessary.

Further, in most companies I work with, their EMS programs can be done with no cost, or very little net cost, over several years. That is a big plus. The program requires an analysis of each companies aspects, and requires a commitment to continual improvement. That cannot be done if the intent is only to maintain the status quo. The requirement drives creativity, which produces unique and beneficial solutions. It is one of the few win-win scenarios we get to work with.

 

[Helmut Jilling]

Thank you very much for your discussion of this issue. I have gotten a lot of useful information from it - it almost sounds like the discussion I am having with the registrar. The registrar has indicated that every site has to have at least one significant impact. My response to the registrar is that if the remote sales office identifies a significant impact it will not be in compliance with the corporate procedure. I explained to the registrar that the corporation does not have unlimited resources and that it has focused it resources on those aspects that will have the largest impact (most significant). The corporate procedure is very clear on how aspects are to be ranked for significance. The registrar is sticking to this rule that every site has to have a significant impact and IMHO is not taking a big picture view (corporate) even though there is a multi-site cert in place. Ironic since the registrar does insist that we follow corporate procedures.

Your registar may be over-reaching. A remote location is not a certified site. I believe the FAQ that states there must be at least one aspect identified as significant was referring to the certified site. If the Sales Office is a fully certified site, I would apply the FAQ interpretation. But, I would routinely accept that a remote office would be supporting the Corporate identified significant aspects. I think you have to apply logic and common sense to it. As an auditor, I would also look for obvious, easy improvement opportunities that could be done at the local level, if they exist.

 

[Sidney Vianna]

A remote location is not a certified site.

I think you are mixing IATF rules for TS 16949 with ISO 14001 certification. In an ISO 14001 multi-site certification, EVERY listed site is certified as part of a system.

 

[Helmut Jilling]

I think you are mixing IATF rules for TS 16949 with ISO 14001 certification. In an ISO 14001 multi-site certification, EVERY listed site is certified as part of a system.

Perhaps I am. The distinctions get vague sometimes for those of us who are always out in the field.

But, I think the principle is sound. A remote supporting office to a petrochemical company would be different than a big processing or distribution center. I would look at whether they have their own unique aspect list and legal list, separate from the main sites, or whether they are using the same documents. Most likely as a remote support, they share the same, and I would apply the logic I mentioned before. I would accept that they share the aspects, and share and support the same significant aspects as Corp. If they have developed their own documents, then I would probably expect them to develop their own significant aspects as well.