Is it a must to run EMS for 3 months before initial external audit

[justincheu]

Hi Randy,
Is 14k requires a company to register before its EMS being effected more than 3 months?

Regards

 

[Randy]

What is desired is for the "System" to go through a complete cycle to include internal audits, corrective/preventive actions and management review so that there is evidence the system is functioning.

When I perform Implementation training I tell folks not to wait until they have their system in place before doing internal audits and management review. These tasks need to be getting performed from the beginning.

 

[Jim W]

The ever important Regulatory Compliance Audit

By all means don't forget to complete a regulatory compliance audit prior to the external. I was given a Major because I failed to perform this audit..... even though I could not find the specific shall statment anywhere in the standard......

 

[Randy]

In the '96 version look at 4.5.1.

In the '04 version look at 4.5.2.1.

 

[Jim W]

4.5.1 ....1996

Yep...Read that one .........Still couldn't find requirement to have audit completed prior to initial audit.............

 

[Randy]

If it's not completed how can it be verified for conformance that it has been accomplished?

 

[Jim W]

Well, there's no way that it could be verified without completion......... Just trying to point out that the individual should complete or have one completed prior to the initial, even though there's no written requirement to do so. The requirement states, and I quote " The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations." Unfortunately, it doesn't indicate a requirement to have this completed before the initial.......I was found guilty........ Just trying to pass along valuable information to someone who may be in the same shoes I was in when setting up an EMS.....

 

[Randy]

The expectation is that an organization actually implement procedures (remember Plan-Do-Check-Act?). Read 4.1, the word "Implement" is very clear.

Organizations that want to play silly a$$ games deserve the consequences (not meaning you of course, but I've seen it done).