EMS Auditing - Misunderstanding Aspect Significance

[kalehner]

EMS Auditing

I have found that sometimes an auditee will do a good job of listing aspects but misunderstand the designation of significance. They sort of play a game with this and try to artificially limit the number of aspects they identify as significant. They believe this will help them in the audit because they only have to manage the aspects that are significant and they can only be audited on significant aspects.

During the audit you find that there are operational controls in place for insignificant aspects but because they are insignificant you cannot assess these. In cases like that I am tempted to write in the report;

The auditee appears to have chosen to limit the number of aspects identified as significant with the purpose of limiting the scope of the EMS audit. This has resulted in some aspects which should be considered significant to be excluded from the EMS thereby diminishing the effectiveness of the system.

I know this would upset some auditees. The truth hurts. Any comments?

 

[Randy]

I understand where you are coming from, but I tend to be more "liberal" and look towards the "spirit" if not the "letter" of the standard.

Doesn't the system belong to the auditee?

Does the auditee not have the right to determine what are and what are not aspects and which ones are significant?

Doesn't the auditee not have the right to determine how it will address or control aspects, significant or not?

I tend to think that my job is to determine whether or not an auditee is stating what will be done, doing what is stated and providing objective evidence for the performance based upon the requirements of the standard.

I may have missed the portion of my LA training where I am to judge the efficiency or effectiveness of the system. In fact give me some time and I will try to identify where those requirements are in 14001:1996.

We have the possibility of a great topic here. I hope some others join in.

 

[Claes Gefvenberg]

Criteria

They sort of play a game with this and try to artificially limit the number of aspects they identify as significant. They believe this will help them in the audit because they only have to manage the aspects that are significant and they can only be audited on significant aspects.

Ok.. We have to have procedures to determine which aspects are significant and possible to control. That way we set the bar. Following the procedure will give us a number of significant aspects. Fiddling with the procedure can change that number.

Now: How many significant aspects are you able to handle (Resources)? There is a limit to what the organisation can cope with. The number of significant aspects should reflect that. If all goes well we will have a different situation next time we identify our aspects (improvement on the chosen aspects). We should then be able to raise the bar and attack other aspects or set new targets for the previous ones.

Continual improvement....

/Claes

 

[M Greenaway]

Well I dont know ISO14001 in great depth but to me it seems unacceptable that a company could, for example, be pumping raw sewage into a river, but not have to do anything about that because it has chosen not to list it as significant.

If this kind of rationale in choosing aspects and considering impacts is not in ISO14001 then the standard is a complete load of old cr.........

 

[Claes Gefvenberg]

Well I dont know ISO14001 in great depth but to me it seems unacceptable that a company could, for example, be pumping raw sewage into a river, but not have to do anything about that because it has chosen not to list it as significant.

Ah.. But they can't... That would mean two things:

1. They would have so many more significant aspects that they didn't have the resources to adress that problem.
2. They would be breaking all kind of laws and concessions
   [/list=1] In short: A company like that would never be able to get a certificate.... and I very much doubt if they would be permitted to run their process at all.... anywhere.... What I'm talking about is to use your available resources in the best possible way: Go for your worst aspects first, which is basically just common sense.
   
   /Claes

 

[Randy]

The identification and control of aspects is where a lot of non-environmental professional amatuers can cause havoc.

Most people don't know that in the USA any company with the proper permit, issued by the appropriate agency, can pump, discharge, drain or dispose of anything, anywhere.

An aspect, that is being controlled by a permit of sorts, may be considered as not significant by the organization as long as they stay within the permit parameters.

I also seem to remember something like "the aspects related to these significant impacts are considered in setting its environmental objectives." The word "considered" is the operative word here. You can "consider" something without doing anything else and be right. "Consider" means to think about, to weigh it, to judge, to take into account.

Question during an audit "Did you consider X when establishing your O&T's?"

Answer "Yep....we considered it, but we had other pressing issues, which are outlined in our Management Review records."

Nuff said I think.

 

[JodiB]

Unless I've misunderstood what kalehner has said, it appears that the company isn't ignoring these aspects, only that they are artificially limiting the scope of the audit by not including them as "significant aspects".

The controls are there - so the company is applying resources and obviously they consider the aspect significant enough to have established these controls. Why have they excluded them from the scope of the audit?

A registrar auditor can, and will, write up "significant" tests that are cr@p. And if I recall correctly, it did have to do with "effectiveness".

 

[Claes Gefvenberg]

Ouch....

Most people don't know that in the USA any company with the proper permit, issued by the appropriate agency, can pump, discharge, drain or dispose of anything, anywhere.

Ouch..!

Errrr.... That was not quite what I had in mind, of course. I didn't expect that.

/Claes

 

[Randy]

Kinda scary isn't it Claes?

 

[JodiB]

Originally posted by Randy
An aspect, that is being controlled by a permit of sorts, may be considered as not significant by the organization as long as they stay within the permit parameters.

I can't agree with this statement Randy. While it appears that companies are at liberty to use whatever criteria they see fit as a test of significance, for all practical purposes any permitted activity will be a significant aspect by any test. It is not a defensible position that while the aspect is significant to the law and to environmental concerns outside of the company's doors, it is not significant enough to the company to establish and maintain controls within the context of their EMS.

It just ain't gonna happen.

And just because I feel a little bit ornery this morning, I will also point out that it may be considered not significant "as long as they stay within permit parameters", is not anywhere in auditing criteria. So just wondering why you would make that exception, and how you could reasonably expect the company to address this need to stay within permit parameters without including the aspect in their EMS.