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ISO 14001 Registrar Audits: Failure Modes

Common failure modes, interesting I think.

4.5.4 Internal Audit…The schedules and audit plan are not being based upon the environmental significance of activities/products/services.

4.5.4 Internal Audit…Audits aren’t effective because they are not being done throughout the audit cycle, but during specific periods like the 2nd week of one specific month. This leaves the system to not be monitored at any other time (can lead to a 4.5.1 issue also)

4.4.2 Training, awareness, competence…numerous issues, i.e., Top management not provided training regarding their specific requirements; no evidence of auditor competence development; employee competence eveidence lacking; no verification of compentence of trainer’s; poor training planning and implementation; etc…a highly lacking clause when it comes to understanding what it entails.

4.4.1 Structure & responsibility…Top managements roles, responsibilities and authorities are not defined and documented; system wide authorities of personnel lack documentation and definition; little or no resource planning or documentation to support the requirement.

4.3.1 Environmental aspects…aspects and associated impacts of products/services are rarely defined; poor identifcation of future & emergency related impacts (“Have or can have”);

4.5.1 Monitoring and measurement…very little evidence of “evaluating” environmental compliance, I only see the inspection gibberish occuring.

4.5.2 Nonconformances and corrective and preventive actions…doesn’t happen. N/C’s are identified and corrections made, but Preventive measures do not occur. The primary cause is lack of undersatnding of the audit process and it’s importance to improvement. Probably one of the poorest implemented clauses of them all, and where the most value could actuallly be gained. Pitiful.

I’ll stop here.

I had come across the following major non-conformances during certification audits (which I used to conduct as a Lead Auditor) of ISO-14001:

4.2 : Site Environmental Policy issued by Corporate Boss sitting in another continent, who does not carry out the Management Review & the Management Representative does not report to him/her. (This relates to the definition of who is the “TOP MANAGEMENT”)

4.3.1: Product and Service related Aspects are missed (identificaion and assessment);

4.3.1: Clarity on “Aspects” and “Impacts” missing (this also gets reflected in

4.4.2 training and competence)

4.4.3: Decision on communication of environmental aspects NOT RECORDED

4.4.6: No evidence of communication of the organization’s requirements to (& understanding by) contractors and suppliers

4.4.7: Top Management is not trained in emergency procedures / Top Management has not been involved in emergency drills

4.4.7: Confusion between an environmental emergency and an environmental accident; confusion between an environmental emergency/accident and a safety issue

4.5.1: Defining and monitoring of KEY CHARACTERISTICS

4.5.5: EMS Audits - Competence of Auditors carrying out internal audits (ref. for example ISO-19011) & Standard method of carrying out audits (ref. for example requirement of IAF) and audit programmes

4.6: Management Review - Agenda and Outcome do not match

4.6: Management Review - carried out by Management Representative - not by Top management (Top Management does not have time for Management Review!!!)