ISO Most Common Problems May 25, 2000 Underwriters Laboratories Inc. May 25, 2000 Underwriters Laboratories Inc.

4.1 General Requirements –Not a major problem in general but----- –What does the system look like as a whole? –Are there system linkages - example: Does the Emergency Response system result in Corrective Action and/or Preventive Action? –Does the total of the parts equal a system? –Not a major problem in general but----- –What does the system look like as a whole? –Are there system linkages - example: Does the Emergency Response system result in Corrective Action and/or Preventive Action? –Does the total of the parts equal a system?

4.2 Environmental policy –Does not provide a framework for setting and reviewing objectives and targets. –Not available to the public upon request. –Communications path from the public to the policy distributor does not work. –Does not provide a framework for setting and reviewing objectives and targets. –Not available to the public upon request. –Communications path from the public to the policy distributor does not work.

4.3.1 Environmental aspects –Aspects that could be significant have not been considered. –No system to keep the aspects up to date. –Aspects that could be significant have not been considered. –No system to keep the aspects up to date.

4.3.2 Legal and other requirements –Procedure to identify and have access to Legal requirements is not comprehensively applied. (includes all regulations at all levels of Government.) –“Other requirements” have not been considered. –Procedure to identify and have access to Legal requirements is not comprehensively applied. (includes all regulations at all levels of Government.) –“Other requirements” have not been considered.

4.3.3 Objectives and targets –Objectives are not considered for each relevant function and level. –Objectives are established without consideration of: Legal and other requirements Technological options Financial, operational, & business requirements Views of interested parties. –Objectives are not considered for each relevant function and level. –Objectives are established without consideration of: Legal and other requirements Technological options Financial, operational, & business requirements Views of interested parties.

4.3.4 EMS program(s) –Programs do not always include: Responsibility, means and timeframe for achieving objectives and targets. Programs are not implemented. Programs are not amended if projects are subject to new developments, activities, products or services. –Programs do not always include: Responsibility, means and timeframe for achieving objectives and targets. Programs are not implemented. Programs are not amended if projects are subject to new developments, activities, products or services.

4.4.1 Structure and responsibility –Responsibilities have not been documented for everyone in the EMS especially at lower levels of the system. –Cannot demonstrate that financial resources are provided to run the EMS. –Top management has not appointed a Management Representative. –Responsibilities have not been documented for everyone in the EMS especially at lower levels of the system. –Cannot demonstrate that financial resources are provided to run the EMS. –Top management has not appointed a Management Representative.

4.4.2 Training, awareness and competence –Training needs have not been identified. –Lack of training records for everyone whose jobs can have a significant impact. –Employees do not know the environmental consequences of non- conformance. –Training needs have not been identified. –Lack of training records for everyone whose jobs can have a significant impact. –Employees do not know the environmental consequences of non- conformance.

4.4.3 Communications –Procedure for external communications does not cover receiving, documenting and dealing with a possible response to external interested parties. –No record of a decision to communicate or not communicate about the significant aspects. –Procedure for external communications does not cover receiving, documenting and dealing with a possible response to external interested parties. –No record of a decision to communicate or not communicate about the significant aspects.

4.4.4 EMS documentation –Does not provide direction to related documents.

4.4.5 Document control –No provision for periodic review for adequacy even if they are not revised. –Current, approved versions of procedures are not always in use. –Obsolete procedures have not been removed from use and identified as obsolete if kept. –No provision for periodic review for adequacy even if they are not revised. –Current, approved versions of procedures are not always in use. –Obsolete procedures have not been removed from use and identified as obsolete if kept.

4.4.6 Operational control –Lack of documented procedures to control operations for significant aspects. –Procedures related to communicating requirements to suppliers and contractors are not implemented. –Lack of documented procedures to control operations for significant aspects. –Procedures related to communicating requirements to suppliers and contractors are not implemented.

4.4.7 Emergency preparedness and response –Procedures do not cover a method to identify the potential for emergencies. –No system to review and revise procedures after an emergency. –No evidence that procedures are tested where practical. –Procedures do not cover a method to identify the potential for emergencies. –No system to review and revise procedures after an emergency. –No evidence that procedures are tested where practical.

4.5.1 Monitoring and measurement –Lack of documented procedures for monitoring “key characteristics.” –Lack of a documented procedure for periodically evaluating regulatory compliance. –Lack of documented procedures for monitoring “key characteristics.” –Lack of a documented procedure for periodically evaluating regulatory compliance.

4.5.2 Nonconformance and corrective and preventive action –Responsibility for investigating nonconformances is not defined and documented. –Lack of evidence of both corrective and preventive action. –Responsibility for investigating nonconformances is not defined and documented. –Lack of evidence of both corrective and preventive action.

4.5.3 Records – All EMS records are not identified. –Identified records do not have defined retention times. –Records do not show conformance to all requirements. (objective evidence.) – All EMS records are not identified. –Identified records do not have defined retention times. –Records do not show conformance to all requirements. (objective evidence.)

4.5.4 EMS Audits –EMS Audits are not comprehensive prior to Registration. –Accreditor Requirement - EMS audits must cover all clauses in all applicable areas with one full cycle prior to Registration. –EMS Audits are not comprehensive prior to Registration. –Accreditor Requirement - EMS audits must cover all clauses in all applicable areas with one full cycle prior to Registration.

4.6 Management review –Review does not include a review for suitability, adequacy and effectiveness. –Lack of a process to collect the necessary information to do the review. –The review does not include the Policy and Elements of the EMS. –Accreditor Requirement - Management review must cover one full cycle prior to Registration. –Review does not include a review for suitability, adequacy and effectiveness. –Lack of a process to collect the necessary information to do the review. –The review does not include the Policy and Elements of the EMS. –Accreditor Requirement - Management review must cover one full cycle prior to Registration.

Pitfalls The environmental manager or quality manager cannot do this alone. Don’t assume your system is acceptable because it conforms to regulations. Don’t assume you conform to ISO because you have equivalent ISO 9000 or QS 9000 systems. The environmental manager or quality manager cannot do this alone. Don’t assume your system is acceptable because it conforms to regulations. Don’t assume you conform to ISO because you have equivalent ISO 9000 or QS 9000 systems.

Pitfalls Don’t assume that you can demonstrate conformance to a requirement. –You may not actually conform. –You may not be able to show an auditor that you conform objectively. Don’t assume you have a procedure if it is not documented. What is the objective evidence of the procedure? Don’t assume that you can demonstrate conformance to a requirement. –You may not actually conform. –You may not be able to show an auditor that you conform objectively. Don’t assume you have a procedure if it is not documented. What is the objective evidence of the procedure?

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