Evaluation of Compliance - Corrective Action - ISO 14001:2004 - 4.5.2 & 4.5.3

[whalertim]

Guys, 4.5.2 Evaluation of Compliance. From what i understand, this is all new.
Nonconformity, corrective action and preventive action has been chanced to 4.5.3. Is this correct?

Also, I need to write a new procedure for 4.5.2. I am looking for ideas on this. Where to start.

Tim

 

[Randy]

Evaluation of compliance is not "NEW", it just has its own clause now. 4.5.2 used to part of 14K'96 4.5.1. Just look upon this requirement as a way to state, perform and document your environmental regulatory compliance inspection process. You need to also do the same thing for your "other requirements". Both can be performed at the same time. We've had a bit of discussion on this and it isn't a big deal. Don't make it one.

What's to write? How do you know and verify that you are meeting yoyr compliasnce requirements?

BTW...The procedure is not required to be documented unless your system requires it.

You're correct about 4.5.3...the requirement is the same.

 

[whalertim]

Randy,
I am missing something here. are you saying that I do "not" have to show a documented procedure for 4.5.2? In looking back into my ISO14001:2004 Internal Auditor Training manual, it has a check list that states for 4.5.2 "Has the operation maintained a "documented" procedure for periodcally........

Just asking, and at the sametime, trying to understand.
Tim

 

[whalertim]

I may have figured it out.

I do not have to have a documented procdure for 4.5.2, but I do need to referance it in 4.3.2 "Legal and other requirements". This way I can cover both requirements under one procedure.

Tim

 

[mike101338]

I do not have a documented procedure for this and was ok with the registrar.
What I showed our auditor was the results of an external environmental compliance audit performed by a local company. This audit provided me with a list of all applicable legal requirements and defined how we stand regarding compliance with each. The auditor accepted this, once he reviewed how we approved him as a supplier.

We perform this external compliance audit on an annual basis.

 

[Paul Simpson]

If you know what is needed audit can cover

I do not have a documented procedure for this and was ok with the registrar.
What I showed our auditor was the results of an external environmental compliance audit performed by a local company. This audit provided me with a list of all applicable legal requirements and defined how we stand regarding compliance with each. The auditor accepted this, once he reviewed how we approved him as a supplier.

We perform this external compliance audit on an annual basis.

For a couple of companies I work with (and a couple of others I have audited) the system has been set up that internal audit evaluates legal compliance. So if there is a legal requirement

• to have waste carriers leave paperwork that shows they have taken waste away (as they have to in the UK) then the audit checks to see that this process is taking place
• if the organisation needs a waste water permit then the audit checks that it is there and that the periodic checks show the waste water is in compliance

 

[Randy]

Documented procedures are only "required" by 4.4.6 Operational Control.

Most of the other clauses require a "procedure" to be implemented and maintained, but not documented. When you think of procedure in this context think of a process or method of doing something.

I'm a firm believer in documentation, but not in over-kill. Too many systems I see have been over engineered and over documented making them unwieldy and cumbersome.

 

[mike101338]

The only caution to having your employes perform the task of determining compliance is you will need to show they have the necessary skills/training to make that assessment.

 

[Randy]

It's called "Competence" Mike and falls under 4.4.2 requirements. It applies to employees and eveyone else working on your behalf.

 

[mike101338]

It's called "Competence" Mike and falls under 4.4.2 requirements. It applies to employees and eveyone else working on your behalf.

As long as it doesnt apply to me!