ISO 14001 Environmental Scope - Auditor Pushing Us to Expand it!

[Steve Z - 2008]

Our surveillance auditor is pushing for us to expand our environmental scope declaration.
Does anyone have a scope that I can peruse.

Steve Z.

 

[Sidney Vianna]

Re: ISO 14001 Environmental Scope

Our surveillance auditor is pushing for us to expand our environmental scope declaration.
Does anyone have a scope that I can peruse.

The scope of certification should reflect the system being certified. Normally, the scope of certification is agreed between the Certification Body and their client, early on. For an auditor to suggest that your EMS scope of certification should be expanded, s/he must have some indication that the current certificate does not really reflect the system being certified. If that is the case, s/he should have let you know CLEARLY what is the concern about the scope of certification, so you can implement a correction.

So, did your auditor indicate what is missing?
PS The ISO 14001 certificate, displayed at your website, is outdated now.

 

[Steve Z - 2008]

Perhaps I was too brief.
This is not the scope of the certification by the scope required in 4.1 - General Requirements.
He stated that our scope declaration was fine for the previous version of 14001 but not for the current version.
The Environmental Scope which we show in our Manual states "Our EMS provides a mechanism for environmental management throughout our organization. The EMS is designed to cover all aspects whcih we can control and directly manage, and those we can influence while not directly controlling them."
The Auditor stated that we needed to add things that are specified in 4.3.2 & 4.3.3 plus include that we will do corective and preventive action when a nonconformity (or potential) is found during an audit. Also it needs to define boundaries which include physical, system and interfacial.
The last statement about boundaries is what has me stumped.

 

[Steve Z - 2008]

Re: ISO 14001 Environmental Scope

Thanks for the comment about our web site. I'll remind IT.

 

[Randy]

Perhaps I was too brief.
This is not the scope of the certification by the scope required in 4.1 - General Requirements.
He stated that our scope declaration was fine for the previous version of 14001 but not for the current version.
The Environmental Scope which we show in our Manual states "Our EMS provides a mechanism for environmental management throughout our organization. The EMS is designed to cover all aspects whcih we can control and directly manage, and those we can influence while not directly controlling them."
The Auditor stated that we needed to add things that are specified in 4.3.2 & 4.3.3 plus include that we will do corective and preventive action when a nonconformity (or potential) is found during an audit. Also it needs to define boundaries which include physical, system and interfacial.
The last statement about boundaries is what has me stumped.

Your auditor is full of tripe (or any othe word you'd like to insert)................If he has issue with this he can contact me.

All your scope has to do is establish the boundaries of your EMS. It looks to me that he doesn't know the difference between the Scope and the Policy requirements.

Boundaries....."Our management system will encompass everything we do, we use and that we make".

Look at this Scope from The Missouri University of Science and Technology(Missouri S&T)

The Scope of the EMS:
The Environmental Management System of the Univeristy of Missouri - Rolla (Missouri S&T) includes educational, research and administrative activities on the Missouri S&T Campus.


Here is the Scope of the EMS for EPA Region 7

Region 7 EMS Scope

The scope of the Region 7 EMS covers all activities undertaken in our facilities located at:

901 North 5th Street, Kansas City, Kansas (Regional Office)
300 Minnesota Avenue, Kansas City, Kansas (Science & Technology Center)
Hunt Midwest Subtropolis, 8600 Roadway, Building 81C, Kansas City, Missouri (warehouse facility)
Various field locations in Missouri, Nebraska, Kansas, and Iowa
It also includes how we travel to and from various field locations in Missouri, Nebraska, Kansas, and Iowa and our ability to provide alternatives to single occupant vehicles for our employees as they commute to and from work.

 

[AndyN]

I agree with Randy. When any (external) auditor 'suggests' that something like a scope be expanded, there's uncertainty and if there's a requirement in one of those clauses mentioned, then an NC/OFI or whatever can be written.

Tripe is right! With onions..........

 

[Sidney Vianna]

The Auditor stated that we needed to add things that are specified in 4.3.2 & 4.3.3

Where is the shall?

plus include that we will do corective and preventive action when a nonconformity (or potential) is found during an audit.

Obviously your EMS must do those things. But to require that is declared in some type of scope definition is nonsensical, imo.

Also it needs to define boundaries which include physical, system and interfacial. The last statement about boundaries is what has me stumped.

Annex A (INFORMATIVE, not NORMATIVE) of ISO 14001:2004 states

An organization has the freedom and flexibility to define its boundaries and may choose to implement this International Standard with respect to the entire organization or to specific operating units of the organization. The organization should define and document the scope of its environmental management system. Defining the scope is intended to clarify the boundaries of the organization to which the environmental management system will apply, especially if the organization is a part of a larger organization at a given location. Once the scope is defined, all activities, products and services of the organization within that scope need to be included in the environmental management system. When setting the scope, it should be noted that the credibility of the environmental management system will depend upon the choice of organizational boundaries. If a part of an organization is excluded from the scope of its environmental management system, the organization should be able to explain the exclusion. If this International Standard is implemented for a specific operating unit, policies and procedures developed by other parts of the organization can be used to meet the requirements of this International Standard, provided that they are applicable to that specific operating unit.

From what I gather, your organization is a single site, boundary-defined company. If the external auditor has concerns about the scope of application of your EMS, s/he is not making it clear where the (potential?) problem lies.

 

[Randy]

Perhaps I was too brief.

The Auditor stated that we needed to add things that are specified in 4.3.2 & 4.3.3 plus include that we will do corective and preventive action when a nonconformity (or potential) is found during an audit. Also it needs to define boundaries which include physical, system and interfacial.
The last statement about boundaries is what has me stumped.

4.3.2 is the requirement to identify regulatory and other requirements relevant to your aspects

4.3.3 is to establish documented objects and the planning necessary to achieve them while taking into account your aspects and regulatory and other requirements

4.5.3 is the corrective and preventive actions requirement

When you commit yourself to meeting applicable regulatory and other requirements in your Policy you have already commited to meet the requirments of 14001 (ISO 14001 is an "other requirement"). When you commit to meeting the requirements of 14001 the committment to perform corrective and preventive actions is automatic in the Policy and does not need to be done again... I'd give your auditor a DUH on that one and I'd say it to his face.

Therefore all you need to do is to provide the evidence of meeting your committments by addressing the requirements (through your documentation) and your fulfillment (through your records).

 

[Helmut Jilling]

4.3.2 is the requirement to identify regulatory and other requirements relevant to your aspects

4.3.3 is to establish documented objects and the planning necessary to achieve them while taking into account your aspects and regulatory and other requirements

4.5.3 is the corrective and preventive actions requirement

When you commit yourself to meeting applicable regulatory and other requirements in your Policy you have already commited to meet the requirments of 14001 (ISO 14001 is an "other requirement"). When you commit to meeting the requirements of 14001 the committment to perform corrective and preventive actions is automatic in the Policy and does not need to be done again... I'd give your auditor a DUH on that one and I'd say it to his face.

Therefore all you need to do is to provide the evidence of meeting your committments by addressing the requirements (through your documentation) and your fulfillment (through your records).

I agree with randy's explanation. I think what the auditor intended may not be clear. The boundaries may refer to the scope statement needs to describe what is included under the system. My clients usually describe is as the facilities that are included at the address, the buildings and outside aspects. Something along those lines.