Environmental Aspects of Products - A forgotten issue in ISO 14001 Audits?

[Dr. L. Ramakrishnan]

Dear Samsung,

Kindly allow me to "disagree" with your thesis.

No doubt; the scope of the management system is defined by the organization. But within the scope, say manufacturing, all products, activities and services have to be included in the system. What do you manufacture ? Product? If you do not consider the product in the scope, then it is like separating the body and soul when you refer to a person. If the product that you manufacture has environmental impacts they have to be considered in the system. The product, once manufactured, is handled, stored and transported in/from your factory. You cannot say these activitles are not included in the scope of the system. Assume that you manufacture Hydrocholoric acid; can there be a ISO-14001 for the organization without considering the handling, storing and transportation of hydrochloric acid ? Assume that you are manufacturing electronics products; can you say that the design that requires ROHS compliance is not a part of the ISO-14001 system ? If you do not control this through an operational control procedure you will end up with products not meeting RoHS directives resulting in huge liability to the organization.

We have to be very clear; there are three major reasons for establishing an ISO-14001 (apart from the customer requirement, and other reasons cited in the Standard and general literature); they are: (a) reduce the risk to the organization, (b) improve the opportunity to the organization and (c) improve the image of the organization. If an ISO-14001 EMS neglects any or all of these, then it is only a paper system, which does not add value to the organization.

As indicated in my earlier post a certification agency may not approve of a paper system and will ask the organization to address issues that are relevant to the organization (within the scope as defined by the organization).

With kind regards,

Ramakrishnan

 

[samsung]

Infact all the manufacturing aspects, in one way or other ultimately correspond to the product being manufactured. If no product is to be produced, there will be no aspects and no resulting impacts on the environment.

All the aspects related to product during its production have to be considered within the EMS but if the scope is limited to manufacturing only, then I doubt if a CB would query into the environmental aspects of its transportation and handling (post manufacturing activities). Obviously when a product is manufactured, it has to be transported, handled and even marketed and sold to the end users but all of which may not necessarily fall under the mandatory purview of EMS as an inherent requirement. Suppose the company A transports all of its products through railways which is a state owned organization whose own environmental performance is under question or through a road carrier with no environment policies at the first place but these are thought to be the most cost effective & productive ways of transportation. Under such a scenario, it will be counter productive for Company A to state in its env. policy that they will not use railways or that particular road carrier as the preferred mode of transportation.

Assume that you are manufacturing electronics products; can you say that the design that requires ROHS compliance is not a part of the ISO-14001 system ? If you do not control this through an operational control procedure you will end up with products not meeting RoHS directives resulting in huge liability to the organization.

No one will disagree that any 'legal and/or other requirement' such as RoHS will not form part of the organization's EMS. The organization has to comply with those mandates even without having an EMS in place.

 

[Howard Atkins]

Some could disagree with that stance. For example, a car manufacturer: isn't the fuel consumption of the car a significant e-aspect? During the car life cycle, if the fuel consumption was increased by 10, 12, 15 %, imagine how many gallons of fuel would be saved? Multiply that by the millions and you can easily account for a significant reduction in GHG emissions... The new standard is "cradle to cradle". Recycle, recycle, recycle....

I have whilst auditing piston and similar engine parts had examples of design to reduce oil consumption and also reduction of fuel use.
They are also designing ring blanks with smaller diameters to save machining which uses energy and produces scrap.

Here again the distinction between Quality and Environmental targets is meaningless.
By definition reduction of scrap-a quality objective saves energy and waste.
The same target for both standards.