ISO 50001 Interpretation of section 3.3.9 (Outsourcing)

[Ben B]

Hi there (my first post!),

I am currently integrating the ISO 50001 standard, but following a discussion with an auditor, I could do with some guidance/clarification. I also couldn't find any similar posts using the search button.

(As a quick summary!) I have completed our energy review, established baseline data and have created a system for reviewing and updating our EnPI's. So we are quite far into our EnMS development.

However, I was recently told that the energy consumption of our sub-contractors (mainly haulage) has to be accounted for in our energy review. I believed this would be out the scope due to their energy use whilst delivering to be out of our immediate control. Due to this, I am slightly confused as the best way to monitor this going forward, or what the standard requires me to do to account for these energy uses. So my questions relate to how to interpret section 3.3.9 Outsourcing

A few issues with this are apparent to me:

1. Can I exclude subcontracted work from my scope?
2. Do I simply need to monitor subcontractor energy use for say, Haulage, (as an example by asking them to send me a spreadsheet detailing the litres of petrol consumed whilst on a delivery for us per month), and documenting this data per year on the same spreadsheet that I use to measure the businesses total energy use?
3. Do I need to implement them into site's EnPI?
4. Do I just need a commitment to use the most efficient trucks and routes where possible going forward etc?

Thank you in advance for those that take the time to read and reply, I look forward to hearing from you.

Kind Regards,

Ben

 

[Sidney Vianna]

However, I was recently told that the energy consumption of our sub-contractors (mainly haulage) has to be accounted for in our energy review. I believed this would be out the scope due to their energy use whilst delivering to be out of our immediate control.

Whoever told you that, is wrong. The second to the last paragraph of ISO 50001:2018, 4.3 clearly stipulates:

"...The organization shall ensure that it has the authority to control its energy efficiency, energy use and energy consumption within the scope and boundaries. The organization shall not exclude an energy type within the scope and boundaries..."

Although you can INFLUENCE a subcontractor towards energy efficiency improvement, you cannot control it.

 

[Ben B]

Hi Sidney, thanks for your reply.

The issue we face is that if these sub-contractors are exclusively delivering our product, using traffic routes that we provide, then technically aren't we dictating the energy use of their vehicles?

 

[Sidney Vianna]

In my opinion, you are not controlling their energy use. You are influencing it. The degree of influence is high, but not control. If you start sliding on this slippery slope of allowing scope creepage over your EnMS, it is an endless process. Today, it will be the haulage vendor, tomorrow, someone will try to convince you that the landscaper vendor is part of your EnMS.

But, good luck to you. Not many people here to discuss ISO 50001 and EnMS's. Hopefully other people will chime in.

 

[Ben B]

I agree with that, and I feel that trying to collate this information would take an awful lot of time for not very much gain. Especially when a company can do very little to control a sub-contractors energy use except declare that energy conscious businesses will be used going forward.

To play devils advocate, however. If this wasn't tracked, could a company going for ISO 50001 simply begin to sub contract all of its deliveries, claiming an energy improvement from the year before, when really the energy consumption has just been offset to sub-contractors?

 

[x-files]

However, I was recently told that the energy consumption of our sub-contractors (mainly haulage) has to be accounted for in our energy review.

In my opinion, the auditor was right. Energy review is a complex approach, and it just has to document (be aware of) the amount of energy you are using for such important process like "delivering your product", outsourced or not. That's the absolute mandatory process in your organization, and you can make (change) decisions over years to outsource it or to have your own transport fleet.
The auditor who told you that, had this in mind:

8.1 Operational planning and control: [...]
The organization shall ensure that outsourced SEUs or processes related to its SEUs (see 6.3) are controlled (see 8.3).

You have to include that (outsourced) energy consumption in formula to figure out is it SEU or not, and to control it at least by 8.3.

And now, forget the standard. You are establishing the energy management system, not to satisfy auditors, but for your organization benefits. Do you want your system to be blind on the energy use and consumption of product delivery process? I don't think so... At least that can be your own requirement to make smart decisions in the future (joke: electric vehicles, planes, drons, horses )...