ISO 14001 Clauses 4.5.1 & 4.3.2 - Evidence of legal/customer requirements compliance

J

Jaco

Evidence of law/customer requirement compliance

Hey,

We got an improvement note as our assessor pointed out that only signed an environmental agreement and a Non-use warranty is not acceptable for clause 4.3.2. Even though, I showed some testing report (performed by an accredited laboratory) for part of our products to them to demonstrated our parts free from prohibit substance. Is it debatable? I don’t how to get the compliance evidence for all of our products, send all of our products to laboratory for testing obviously is impossible. Any one has some idea on it? :confused:
 

Randy

Super Moderator
OK lets get this straight.....

This assessor gave you an opportunity for improvement for something that you have already done?

4.3.2 Requires you to identify and have access to applicable legal requirements related to your "aspects" and any other applicable requirements (industry codes, customer, etc...). Those aren't the exact words, but they are close enough. I'm having a hard time finding where you are required to do anything else in 4.3.2 but that.

4.5.1 requires you to evaluate your legal compliance...so on and so forth

Guess what? I can't find anywhere that you need to do anything with the "other requirements".


If you can show evidence that none of your products have significant aspects assigned to them, that they meet legal and any other requirements, I'd say you have done your job and so has your organization.

Ask for clarification and for a requirement.
 

Wes Bucey

Prophet of Profit
Randy said:
If you can show evidence that none of your products have significant aspects assigned to them, that they meet legal and any other requirements, I'd say you have done your job and so has your organization.

Ask for clarification and for a requirement.
I'd say that Randy has his finger right on the basic solution for most disputes about auditor findings, regardless of whether they are internal, second party, or third party registrars:
Ask for clarification and for a requirement!

In most cases, the individual auditor has a plausible explanation and can cite chapter and verse in a Standard, along with a list of interpretations by other experts. After all, the auditor is the guy who is on the site making his observation in real time, versus the "edited" version we get here in the Cove.

In those instances where the auditor merely misinterpreted either the Standard or what he was seeing, it's often simple enough to ring in the auditor's supervisor to arbitrate the situation.

The time to get hot and bothered and to consider recourse to outside arbitration or adjudication is when the auditor gets haughty and says something to the effect:
"Who are you going to believe? My word? or Your da*n eyes?"
 
J

Jaco

Randy said:
This assessor gave you an opportunity for improvement for something that you have already done?

this assessor GAVE me a minor nonconformity(they use improvement note instead of minor nonconformity note), which means it must be cloused in next visit, otherwise ....

Randy said:
If you can show evidence that none of your products have significant aspects assigned to them, that they meet legal and any other requirements, I'd say you have done your job and so has your organization.

Ask for clarification and for a requirement.

Randy, thanks for help. :thanks: btw i would like to know what the common approach for that evidence. Or just one way --take a few parts for testing(like me)?
 

Randy

Super Moderator
Well 1st of all, if none of your product has a significant aspect assigned to it, based upon your criteria and methodology, there is nothing you need to do.

2nd... if you have identified what the legal requirements are that are related to your activities, products/services; you have developed procedures to comply with them; you communicate the requirements and how they need to be met to the relevent personnel; you evaluate your legal compliance and take necessary C/P actions; and all this good stuff can be verified through documentation or whatever, you've nothing else to prove or do.

3rd...if you have identified the "other" requirements that you need to meet and go through the same basic process as stated above, the end result is the same...you're done. The deal with "other requirements in 4.3.2" is 14001 only requires you to identify and have access to them, everything else you need to do is ambiguous and left to interpretation at best. My suggestion is to follow the same process as the legal one.
 
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