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ISO 14001:2015 accredited but import most product - CB Raised minor NC on Life Cycle Perspective

#1
Hi, We import most of our product and do some small assembly here on site. The CB raised a minor non conformance that we had not done a lifestyle perspective and we needed to. This was what the CB wrote:​
"The organisation has not ensured that requirements that can lead to environmental impacts are considered for each stage of the product lifecycle (cradle to grave approach)​
a) Determine procurement requirements based on the environmental impacts identified through the lifecycle assessment and communicate the requirements to external suppliers and contractors, including those that carry out the design and development of the products ensuring they have considered each stage of the product lifecycle (cradle to grave approach)​
b) Communicate to the customer potential significant environmental impacts associated with transportation/delivery, use, end-of life treatment and final delivery" So they want to see everything from our head office.​
The lifecycle should only be based on what we do here on our accredited site as we have no control over HO design, raw materials etc, am I right in this thinking?​
 
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Randy

Super Moderator
#2
The lifecycle should only be based on what we do here on our accredited site as we have no control over HO design, raw materials etc, am I right in this thinking?​
Yep, you're correct. 6.1.2 requires you to "consider" life cycle but does not mandate a formal, documented life cycle analysis (refer to A.6.1.2). There's nothing about communication of significant environmental impacts to customers (in the USA this more often than not is done with Safety Data Sheets that are OSHA and not EPA required documents under 29CFR 1910.1200). Now there may be some legal obligations for labeling, providing safe use instructions and so forth, but that's also already covered.

This looks pretty far reaching when you step back from it and maybe a bit of overreach and vague... (requirements that can lead to environmental impacts are considered for each stage of the product lifecycle (cradle to grave approach). Everything you do from making your widgets can lead to environmental impact...Everything! So where do you start and where do you end?

The word “consider” means it is necessary to think about the topic but it can be excluded; (A.3)
 

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