Significant Aspects required by Auditor for Water and Energy

[abhaygirish]

Re: Significant Aspect

If you cannot reduce actual water consumption, you can propose the metrics as, say, water consumption per piece of product or related to turnover or... just think about something reasonable.

Yes we calculated water consumption / kg but that also remain static one.

Actually I want put one more question ...

When mgt desire to launch any new poduct that time in validation itself we got clearcut idea ( about exact Quantity) about Hazardous waste. and same information we furnish to Pollution Contol Board .

Now my query is how auditor ( from Reputed cert.body ) can remark that production function to look for reduction in haz waste by taking objective.

Reards
Abhaygirish

 

[Randy]

Now my query is how auditor ( from Reputed cert.body ) can remark that production function to look for reduction in haz waste by taking objective.

Here's a different take on your question...It's not any of the auditors business what you identify as significant or how you do so and the absolutley have no right telling you what is or is not significant....The auditors have gone way out of bounds and have crossed the line if what you are saying is in fact what happened. If an auditor on my team had said that there would be a severe closed door discussion with him/her and I would ask you to please excuse the comment.

 

[Dr. L. Ramakrishnan]

Randy is absolutely right in pointing out that the situation you presented is an example of an auditor acting like a "consultant" during the audit process; in the context of an ISO-14001 audit the auditor is not supposed to suggest improvements. Once I got a "minor" non-conformance from the Accreditation Witness Auditor (RvA) for suggesting an improvement option to an auditee.

 

[db]

Here's a different take on your question...It's not any of the auditors business what you identify as significant or how you do so and the absolutley have no right telling you what is or is not significant....

I concur.. I could argue that both water and electricity are aspects, but the decision of whether they are significant, and what (if anything) is to be done with them is up to the company. The only other possible factor could be whether the usage of water or electricity somehow related to a legal or other requirement, but even then, that would not necessarily mean they were significant.

 

[samsung]

But auditors are insisting that both are sig.aspect & we should take objective on it . kINDLY GUIDE

-Abhaygiish

This is possible only when you yourself have determined your aspect as being 'significant' based on your own criteria, else the auditor, as Randy very correctly said "It's not any of the auditors business what you identify as significant or how you do so and the absolutely have no right telling you what is or is not significant...."

Please revisit your aspect identification sheet and see how (on what criterion) you have determined the significance level of your aspects. Please tell more of the yardstick you used to rate the aspects.

 

[abhaygirish]

samsungji ...

Thanx . I'll revert with criteria for sig. & non sig.

Thanx
Abhay

 

[Paul Simpson]

Here's a different take on your question...It's not any of the auditors business what you identify as significant or how you do so and the absolutley have no right telling you what is or is not significant....The auditors have gone way out of bounds and have crossed the line if what you are saying is in fact what happened. If an auditor on my team had said that there would be a severe closed door discussion with him/her and I would ask you to please excuse the comment.

OK, Randy. We've disagreed on this in the past but I'll state my case again - exaggerated for effect!

If you operate a nuclear power plant and as a consequence generate radiation and nuclear waste you cannot state that these impacts are not significant.

This is blindingly obvious to the man / woman in the street so shouldn't escape the attention of a trained auditor.

I've been here. I audited a multi site automotive company making product with very little waste. Their real environmental impact was with the transport of these components around Europe and North Africa but it wasn't acknowledged ... guess what - nonconformity.

I accept it is not the auditor's position to define significance but if an organization has missed it then they should raise it as a finding.

All of the other stuff in my earlier post about 'you can only do what you can do' still applies!

 

[samsung]

I'll revert with criteria for sig. & non sig.

The standard is very clear when it defines the requirements for identifying environment aspects.

1. that you need to identify the env. aspects of those activities that a) you can control and b) that you can influence

2. that you also need to determine how your legal requirements apply to the identified aspects (you cannot skip identifying an aspect if it's related to one of your legal requirements)

3. that the Significant environmental aspects are those which can have significant impacts on the environment.

4. that you shall take into account (consider) the significant aspects while setting objectives (it doesn't imply that you necessarily set an objective for each of the SA you determined)

Now, it's one thing for an aspect to be 'significant' (on whatever grounds) and quite another to be 'within or out of control'. So in your case, if the consumption of water and electricity is 'within control', i.e. within the specs (either defined by you or by any of the interested parties including a regulatory body), then an auditor has no business to ask why you haven't set an objective to control or reduce it. No need to set an objective since it's already 'in control' (if it's so, based on your budgetary/regulatory norms) and also if it's consistent with your environmental policy.

 

[abhaygirish]

Thanx.... But still confusion is there.

Pls bare my queries...

If my process is validated .... Water is in control ... Energy is in control .. at R&D stage (validation ) poduct life cycle study conducted ... qty of waste defined (solid , liq. gas ) we already done EIA for inclusion of products in PCB' s Consent , still auditors are saying that " we should take improvement project/objective " to reduce haz waste qty , discharge of effluent "
REGARDS
ABHAY

 

[Jen Kirley]

Fresh water and energy are becoming more important as resources all the time, and interestingly fresh water may overtake the criticality of energy within the next generation or two.

Some add improvements to effluents by using "gray water" (from bathroom sinks, for example) for landscaping. Some Middle Eastern municipalities are directing sea water for flushing commodes.

But these arrangements involve infrastructure changes, which may not be worthwhile to you. The auditor is asking that you consider all the aspects because so many forget about aspects in administrative functional areas. I agree the auditor is wrong to demand specifics, but I think it's okay to keep expanding the scope of what the program can address. As time goes by, technology changes and more options become available to us.

So you've done that. You examined your processes and decided you can't conserve anymore. Fine. Then the objective can be, for example, "to maintain current optimum consumption levels per employee/sales/etc."