ISO 14001 & Product Design Process Environmental Aspect Review Requirements

G

Graruss

#1
Hi,
At a recent ISO 14001 audit the Auditor raised a finding regarding the design process. The finding requires a format and identification at which stage of the design process the environmental Aspects and Impacts should be reviewed. Currently we maintain a central register to cover all Aspects and Impacts. The Auditor wants to see an Aspect review within the design process. Does anyone have any examples or template of how this is incorporated into the design process or any experience of similar audit finding.
 
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R

Reg Morrison

#2
Re: Design process aspect review

Just to make sure: Is the auditor referring to the PRODUCT design and development process?

So, your organization is responsible for the design of the product you manufacture?
 

John Broomfield

Staff member
Super Moderator
#3
Re: Design process aspect review

Hi,
At a recent ISO 14001 audit the Auditor raised a finding regarding the design process. The finding requires a format and identification at which stage of the design process the environmental Aspects and Impacts should be reviewed. Currently we maintain a central register to cover all Aspects and Impacts. The Auditor wants to see an Aspect review within the design process. Does anyone have any examples or template of how this is incorporated into the design process or any experience of similar audit finding.
Graruss,

Design introduces new products and processes (environmental aspects) that may have or could have a significant impact (beneficial or adverse) on the environment.

This fact makes your corporate EIA inaccurate or incomplete after each new design or design change.

Already your designers, being competent, know what materials to use to improve beneficial impacts and to avoid to reduce adverse impacts.

But you may need to update your design procedures to reconsider your EIA when design introduces new input materials and during design reviews. The design review records would show this was done. And, as part of the design plan, validation would not be complete until the EIA is re-run and updated to determine the need for any new competencies, controls or objectives in common with any change in the significant aspects.

It seems to me to be more about modifying your design process than introducing a new template to show an auditor.

Better to update the EIA than to create a separate sub-EIA.

John
 
G

Graruss

#4
Re: Design process aspect review

Yes, we design and manufacture air and gas handling equipment. While we will design the most efficient product for the customer's requirements they do not always want best efficiency due to cost or preference of materials or ancillary equipment such as drive motors and pumps etc.
 

John Broomfield

Staff member
Super Moderator
#5
Re: Design process aspect review

Yes, we design and manufacture air and gas handling equipment. While we will design the most efficient product for the customer's requirements they do not always want best efficiency due to cost or preference of materials or ancillary equipment such as drive motors and pumps etc.
Garuss,

Then your product has mostly beneficial environmental impacts? And you have evidence of your attempts to influence customers in making choices that are even better for the environment?

BTW, ISO 14001 does not specify "best efficiency" from your customers.

John
 

kgott

Quite Involved in Discussions
#6
Hi,
At a recent ISO 14001 audit the Auditor raised a finding regarding the design process. The finding requires a format and identification at which stage of the design process the environmental Aspects and Impacts should be reviewed. Currently we maintain a central register to cover all Aspects and Impacts. The Auditor wants to see an Aspect review within the design process. Does anyone have any examples or template of how this is incorporated into the design process or any experience of similar audit finding.
Interesting. I've never heard of that before.

As I read it what the auditor is getting at are things like:

could parts be made from re-used materials be used?
could a product used in the construction of the air conditioner be substituted by a more environmentally friendly product?
could parts of the air conditioner be reused when the conditioner is finally scrapped?
could the design be changed to enable parts currently used for other items, also be used in the construction of the conditioner?

While we are at it lets look at pre-empting a safety auditor making the same findings.

Has it been designed in a way that ensures it can be installed safetly
Has the way it is be to serviced been designed so it can be done safely?
Are their anchor points built into to enable fall prevention equipment to be used to safe access and egress to and from the ground if might be installed at heights?
Has it been designed for it to be dismantled safety when its finally de-commissioned?

Has it been designed so the owner can install a new pump themselves instead of having to get a contactor in? Sorry, that takes money out of the pockets of the manufacturer or supplier does'nt it,
 
G

Graruss

#7
Looking at ISO 14004 general guidelines 4.1.3.1 it mentions consideration to aspects related to design and development. While these aspects are covered in the general aspects register the Auditor expects to see evidence that they are reviewed per contract. While we offer the best fit solution efficiency (energy consumption) and ancillary equipment to meet the clients specification they may request changes which are less efficient. The product is fully recyclable at end of life. A review process where deviations from the best fit are considered may be the solution but I haven't seen a format which could comprehensively cover all areas. Thank you to all who have contributed to this subject.
 
#8
Hi

This is one of the important subjects of an ISO-14001 system. It requires that aspects related to activities, PRODUCTS, and services are identified and evaluated. In most cases organizations miss identifying aspects/impacts of products throughout their life-cycle.

Design being a part of the life-cycle, most of the impacts of the product are decided at this stage and a good aspect/impact assessment at this stage helps to reduce the total environmental impact of the product.

For example, if you design a product with less material than its predecessor model, impacts related to the mass of the product (e.g. impacts related to material used, process efficiency, production waste, production aids, packaging, transportation, end-of-life issues etc.) throughout the life cycle will be generally reduced. For example, if you design to eliminate / reduce a heavy metal (e.g. Pb, Cd) in your product, the generation of hazardous waste during the manufacturing and end-of-life will be reduced.

To cite a simple aspect and impact identification:

Activity: Design
Aspect: Elimination of lead (Pb) in the product
Impact: reduced air, water and soil pollution due to lead (Pb) at the end of life of the product
(in may countries this aspect is covered under legal requirements)

For product design the following subjects may be considered while identifying aspects and impacts:
1 Mass
2. Toxic Substances (Lead, Cadmium, mercury, PBBE, PBB, heavy metals, chlorinated / brominated fire retardants, etc.)
3. Energy use (during the use phase of the product if it is a Electronic or electrical product)
4. Recyclability (Cradle to Cradle principle)
5. Packaging (mass and avoiding PVC, foams etc.)
6. Longivity (the longer the life of the product, the better is the utilization of resources per unit functional use)

I have not come across many ISO 14001 organizations which have included product related impacts, with respect to storage, packaging, transportation, use and disposal of their products, in their ISO 14001 system. Most of the organizations cover impacts due to the manufacturing of products though.

With kind regards,

Ramakrishnan
 
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