iso 14001
The subtle, yet important point is that during an EMS audit, identified regulatory
noncompliances are relevant only to the extent that they reflect a potential system problem. The
finding therefore is not that the site is out of compliance with a given regulation, but that the
noncompliance means some EMS element is not conformed to. For example, a regulatory
noncompliance can be related to a problem with training, recordkeeping, or monitoring and
measurement.
The EMS auditor is not to do a compliance audit as part of the EMS audit. If, as part of the
statistical sampling to verify EMS element requirements, the auditor identifies a regulatory
noncompliance, he or she treats it as any other evidence. This point has been difficult to accept,
especially in U.S. industry because of our long history of regulatory enforcement. The EMS
auditor needs to constantly remember that compliance auditing is being done separately as part
of the EMS requirements itself (4.5.1, paragraph 3) and to stay focused on the criteria at hand -
ISO 14001 and the site’s EMS. There may be legal requirements regarding noncompliances
encountered during the EMS audit, but this should be decided and addressed in the audit plan.
In summary, the goal of the compliance audit is to verify compliance with regulations, whereas
the EMS audit’s goal is to verify that the EMS conforms to planned arrangements, including ISO
14001.
THE AUDIT
Essential Features of an Audit
The EMS audit incorporates in a condensed form the following general features that are essential
elements of any audit, i.e.:
- They are pre-planned and methodical in nature rather than haphazard
- They should be free from bias or prejudice
- They encompass some form of inquiry and critical consideration of the resultant findings
- They are concerned with all activities that affect environmental issues and with results
reflecting environmental performance
- They should ensure that such activities are carried out in an effective and consistent manner
in accordance with planned arrangements
Why Perform EMS audits?
In order to confirm that the defined EMS system operates effectively, it is essential to carry out
some form of monitoring activity in addition to ongoing monitoring and measurement. Listed
below are some of the potential benefits of adopting EMS audits as the basis of any such
additional monitoring:
- They provide a means of confirming that the EMS policy is understood and is being
implemented.
- They give management confidence that the system is being implemented in the manner
prescribed.
- They provide a structured means of identifying deficiencies in the system, agreeing on
corrective action, and following up to confirm effectiveness.
- They enable system weaknesses to be highlighted before the related potential problems are
reflected in the environmental performance.
- They provide a convenient framework for investigating operations in a particular area, e.g.,
in response to environmental problems.
- Again, if they involve personnel from other areas, the opportunity is created for interchange
of ideas so that successful features of an area’s system can be applied elsewhere if
appropriate.
- They can, by involving personnel more widely in the operations of the business, lead to
increased commitment and motivation.