Many people include it in their Aspects and Impacts. The auditor has no right to specify which format is acceptable. The standard says "consider" which is a very broad term. A good auditor can notice it where it exists, but we hope our clients will direct us to it, describe what they have come up with, show examples if any exist, etc. This can be as simple as chemical substitution, such as cleaning parts in a parts washer using Simple Green versus some carbon based solvent.