darkafar,
In answer to your original post, no you are not meeting the requirement. In response to your second post, it could be a nonconformity. If there is just one or two of your employees that were confused, I would think it was an anomoly. But if there are several employees are confused or do not know, then I would be thinking that there was a break-down in your EMS and it would be a nonconformity.
We have people at every education level at our organization from PHD's to high school drop-outs. Additionally we have a lot of employees that do not speak English as their first language (or barely speak it at all
). We have included a "deviation statement" in all of our operational controls so that the employees know exactly how they would affect the environment if their op. controls are not followed. Additionally, we cover how they impact the environment during training.
When it comes to auditing, I have found that it is easier to start the interview in a logical manner/progression. For example: I will usually ask if we have an environmental policy (this is just to get them in the right frame of mind), then I will ask what it says. They do not need to know it verbatim, just know the intent of what it says and the high points. The follow-up to that is when I ask them how they do it.At first I was getting a lot of blank stares and statements such as "Dude, I run a rivit gun all day. I'm not polluting anything.". Obviously the first few audits were more training than auditing but it also put a spotlight on an area where we were weak in. A couple CARs later and we are much better. The blank stare is now an isolated incident and not the norm. I am a firm beliver that audits are about training as much as fact finding and finding conformance.
Just my
