Supplier Significant Environmental Aspects - Audit Finding

G

Graruss

#1
I am looking for some advice or opinions on an audit finding. We had a minor NC raised regarding suppliers aspects.

?Records sampled do not demonstrate the environmental aspects of goods and services have been identified and requirements communicated to suppliers?.

We send out questionnaires to new suppliers covering 9001, 14001 and 18001 requesting information relating to management systems and certification etc. The Auditor said if the supplier has 14001 they will have evaluated their significant aspects. If they do not have 14001 then we will have to evaluate their significant aspects. We have in excess of 2000 suppliers with less than 5% possessing 14001 certification. If the supplier does not have 14001 they will not necessarily have an understanding of aspects. This appears to be monumental task to address this finding. Does anyone have experience of addressing a similar finding or a practical way to satisfy the clause of the standard? Also how frequently should suppliers questionnaires be updated or resubmitted? Thank you.
 
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Randy

Super Moderator
#2
Re: Suppliers Significant Aspects - Audit Finding

It ain't what's significant to them, it's what's significant to you and has not one thing to do with their status to ISO 14001. If your records do not indicate that you have evaluated what your customer supplies you with, regardless of what it is then you are WRONG!

Based upon your EMS's criteria for significance is anything provided by a supplier significant? Yes or No?

If yes, then provide them your instructions what you want...Such as if they supply you with something that contains ODC's and you cannot have ODC's then tell them you need ODC free material....Or if you've identified broken wood pallets as significant tell them that pallets have to be recyclable plastic....The list goes on.

The questionnaire thing is only as good as long as the products supplied are stable and not changed...as for timing there is no right or wrong and anyone telling you different is incorrect.

As for experience...a couple hundred 3rd party EMS audits for starters
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#3
I am looking for some advice or opinions on an audit finding. We had a minor NC raised regarding suppliers aspects.
It is true that MANY ISO 14001 certified organizations limit their assessment, in terms of aspects and impacts to their operations and fail to assess the incoming products and services.

I am positive the auditor in question is referencing ISO 14001:2004 4.4.6 c). The key issue here is the word APPLICABLE. If, for example, your organization has to comply with the REACH Directive you have to communicate with your suppliers accordingly. If your products have to comply with the ROhS Directive, you need to inform your suppliers accordingly, so their shipments are in compliance.

Have you assessed procured goods and services for their aspects and significance?
 

John Broomfield

Staff member
Super Moderator
#4
Graruss,

Supplied services and products that have significant adverse or beneficial impact on the environment come from decisions made in the design process.

Did your environmental impact assessment include your service, product and process design processes?

Also, it appears that your supplier selection criteria could focus prevention of pollution efforts on the critical few suppliers.

John
 
G

Graruss

#5
Thank you for the replies to my question. As an organisation we buy components from suppliers such as electric motors, instrumentation, fabricated frames and fixings. We do not process substances from suppliers. We design gas handling equipment and assemble the units from supplied components. The supplier questionnaire asks suppliers if they have an EMS and if they have evaluated their significant aspects. The advice I am looking for is (and probably not explained sufficiently) what should we be asking suppliers and to what depth and detail regarding components supplied to evaluate the significance of the aspect? Should we be producing an aspect register for components or per supplier? How have others sufficiently addressed this clause or a similar finding? Is there an efficient way to address this issue considering the number of suppliers involved?
 
#6
Hi

Please consider your suppliers as the extension of your "manufacturing" activity. What is applicable to you is applicable to them too.

Probably the auditor was looking for evidence of your communicating the requirements that may have to be considered at the suppliers' end (activities, products and services) for ensuring that you meet the requirements while using their components. These requirements may be related to (a) Statutory requirements, (b) processes, (c) substances in products, (d) energy use (scope 3) etc.

The following is an example with respect to substances in products.

If you have agreed with your customers certain specific requirements (say RoHS) with respect to your product, you should see that the components that you get from your supplier too meet those specific requirements.

Unless this requirement is communicated to the supplier there is always a possibility that a non-conforming component (i.e. not meeting RoHS requirements) enters your supply chain and that may lead to non-conforming product produced by you.

With kind regards,

Ramakrishnan
 

somashekar

Staff member
Admin
#7
Under the domain of ISO 14k, I do not think what is applicable to an organization is also applicable to its suppliers.
As a policy matter, if you intend to drive the ISO 14k down to your supply chain, you may please do so.
You buy several components ( such as electric motors, instrumentation, fabricated frames and fixings.) as you mention.
Have you considered the environmental aspects of goods and services that have been identified and requirements communicated to suppliers amongst these.
Say, for example the packaging... Have you considered ways and means to reduce or recycle the packaging material with your supplier. Are the packaging material scrap posing a disposal problem to you ? that you are working with your supplier for taking back to reuse or choose some alternate packaging material...
RoHS for me comes from an other regulatory requirement, which indirectly supports ISO 14k. In terms of direct aspects, you need to make a study on the lines of the said example.
 

John Broomfield

Staff member
Super Moderator
#8
Thank you for the replies to my question. As an organisation we buy components from suppliers such as electric motors, instrumentation, fabricated frames and fixings. We do not process substances from suppliers. We design gas handling equipment and assemble the units from supplied components. The supplier questionnaire asks suppliers if they have an EMS and if they have evaluated their significant aspects. The advice I am looking for is (and probably not explained sufficiently) what should we be asking suppliers and to what depth and detail regarding components supplied to evaluate the significance of the aspect? Should we be producing an aspect register for components or per supplier? How have others sufficiently addressed this clause or a similar finding? Is there an efficient way to address this issue considering the number of suppliers involved?
Graruss,

Yes, your designers can determine the environmental impact of each component they specify.

Beyond the legal requirements, you decide the line above which the component has a significant impact or potentially significant impact.

Purchasing can then use ISO 14001 certification as a selection criterion for the suppliers of the few components with a significant impact.

John
 

somashekar

Staff member
Admin
#9
Graruss,

Yes, your designers can determine the environmental impact of each component they specify.

Beyond the legal requirements, you decide the line above which the component has a significant impact or potentially significant impact.

Purchasing can then use ISO 14001 certification as a selection criterion for the suppliers of the few components with a significant impact.

John
John..
I would like to understand what you say, perhaps with an example as I am not clear with what you mention here.
Thanks...
 

John Broomfield

Staff member
Super Moderator
#10
John..
I would like to understand what you say, perhaps with an example as I am not clear with what you mention here.
Thanks...

somashekar,

These days designers are familiar with the Environmental Product Certification schemes for their industry.

Environmental Product Certification is the Google search term but my iPad has stopped copying and pasting as it should, sorry.

These schemes help designers select products with the lowest life cycle costs (usually in terms of tonnes of CO2).

Conversely the organization can obtain this information from their suppliers starting with the components that invoke to highest costs on the environment (perhaps, initially based on their mass).

Building a database of these data is an essential part of knowledge management for continually improving environmental performance.

John
 
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