How have you addressed Cl 4.4.6 Operational Control

[Graruss]

Section C of 4.4.6 Operational control

"Establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organisation and communicating applicable procedures and requirements to suppliers, including contractors".

What is the best practical method or terminology for communicating the organisations applicable procedures and requirements to suppliers and contractors? Is there accepted or standard clauses which can be included within purchase terms and conditions which adequately address this requirement?
How have you addressed this requirement?

 

[John Broomfield]

Graruss,

As a result of your environmental impact assessment you should already know the goods, services and processes that are related to significant beneficial and adverse environmental impacts.

So, ensure the processes responsible for these goods and services are under control to limit adverse impacts and to deliver the beneficial impacts. The process controls may rely on measurements; by calibrated devices of course.

Where these processes are outsourced, your organization is responsible for ensuring they are controlled by your subcontractors (via your subcontracts).

Where these goods and services are supplied, your organization is responsible for ensuring the controls are specified in your purchase orders to your suppliers.

Making the controls contractually enforceable is important because your subcontractors and suppliers are not otherwise obliged to conform to the procedures or specifications.

Your organization will be monitoring conformity and requiring corrections and, possibly, corrective actions if your preventive actions as described above prove to be ineffective.

Your organization will have provided training and have communicated any new controls, possibly, with the reasons why they are in place.

Your organization also must use documented procedures and/or specifications; but only as necessary to ensure effective planning, resourcing, operation, control and monitoring of these processes.

Lastly, you may choose not to sell your products to customers who are incapable of preventing pollution by improper use or disposal of your products.

John

 

[Graruss]

John,
Thank you for your reply. We have assessed the significant aspects of our suppliers through our design review and specifications. What I am unsure of is of a practicable means of communicating requirements or special requirements to suppliers. We currently have Terms and Conditions to cover all other situations but I am unsure of what will adequately address this clause. I have an Auditor who is looking for this to be addressed but cannot explain what he would expect to see and I have been going round in circle trying to address this.

 

[John Broomfield]

John,
Thank you for your reply. We have assessed the significant aspects of our suppliers through our design review and specifications. What I am unsure of is of a practicable means of communicating requirements or special requirements to suppliers. We currently have Terms and Conditions to cover all other situations but I am unsure of what will adequately address this clause. I have an Auditor who is looking for this to be addressed but cannot explain what he would expect to see and I have been going round in circle trying to address this.

Graruss,

I'm sorry to hear you're getting the run around on the specs and procedures for significant goods and services from your suppliers and subcontractors.

These specs and procedures should help determine your supplier/subcontractor selection criteria and should be included with the purchasing documents.

So, the design and purchasing processes and, possibly, the facilities management process should drive these controls to your suppliers and subcontractors when they are responsible for significant goods or services.

...or you can determine what your suppliers and subcontractors are already doing (and planning to do) to prevent pollution and then factor their inputs into a rerun of your environmental impact assessment.

Good luck,

John

 

[Helmut Jilling]

Section C of 4.4.6 Operational control

"Establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organisation and communicating applicable procedures and requirements to suppliers, including contractors".

What is the best practical method or terminology for communicating the organisations applicable procedures and requirements to suppliers and contractors? Is there accepted or standard clauses which can be included within purchase terms and conditions which adequately address this requirement?
How have you addressed this requirement?

I think your question may be too broad and generic without a little more detail. ...but, I will offer a few comments... IF you have specific expectations your suppliers must meet, those should be specified. For example, you can specify they may not use lead, or hex chrome in their process... But, you do not have to attempt to specify how a machining supplier must operate his business. You can specify specific things IF there ARE specific things relevant to your supplier relationship. Or, you can specify encouragement to operate in a more prudent, environmental manner...such as "we encourage recycling wherever it is practical..."