ISO 14001:2015 clause 8.1 on outsourced processes

#1
Hello to everyone,
I would like to get your expert interpretation and advise on ISO 14001:2015 clause 8.1 pertaining to its application on outsourced processes/suppliers.

From the standard:
8.1 Operational planning and control
The organization shall ensure that outsourced processes are controlled or influenced. The type and extent of control or influence to be applied to the processes shall be defined within the environmental management system.
Consistent with a lifecycle perspective, the organization shall:
a) establish controls, as appropriate, to ensure that environmental requirement(s) is (are) addressed for the product or service, considering each life cycle stage;
b) determine its environmental requirement(s) for the procurement of products and services, as appropriate.
c) Communicate its relevant environmental requirements(s) to external providers, including contractors;
d) Consider the need to provide information about potential significant environmental impacts associated with the transportation or delivery, use, end of life treatment and final disposal of its products and services
.

This is my company's current situation:
1. We dont have a purchasing policy to get only ISO14001 certified suppliers or suppliers with an EMS system in place.
2. We dont have resources to audit our suppliers with regards to environmental compliance.
3. Our company don't have business leverage to influence our suppliers to comply.
4. Some of our part designs to have some requirements like use only lead free solder and finished goods having UL and CE marking.
5. We are ISO14001:2015 certified.
6. Most of our suppliers are small scale family owned businesses in Europe and engaged in aluminum die casting and plastic injection and only certified in ISO9001.

What is the best way to manage this clause without being intrusive or mandating controls to the suppliers? We are woried that it might become an issue in the next surveillance/re-certification audit.

Thank you in advance and have a good day.
 
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Sidney Vianna

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#2
It is important not to confuse outsourced processes and suppliers. Look in the Annex A of ISO 14001:2015, section A.8.1, especially the section that describes the components of what constitutes an outsourced process. It includes, among other things, the following critical aspect:

- liability for conforming to requirements is retained by the organization;

in other words, your company would be legally responsible for compliance to the regulations related to the process done by an outside vendor/external party.

So, for example, if you hire a recycler to dispose of your scrap material/shavings, remnants, e-waste, etc... and there are local regulations on what can be sent to a landfill and what can't, you should ensure the contract with the recycler stipulates compliance with such regulations.

As I said, have a look at Annex A.8.1; it should help you.
 
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