iso14000-digest Monday, March 2 1998 Volume 02 : Number 028
----------------------------------------------------------------------
Date: Fri, 27 Feb 1998 05:08:50 -0500
From: Duncan Smith
Subject: as
J Orser's recent reply to Chris Watson's request for help on EMS policy
statements has forced me out of my read-only mode.
>>However, if you are only interested in having a "lipservice" EMS, a
"book-shelf" EMS, then by all
means, copy away. Just one point, don't call me to help you out; I am not
interested.<<
"Just one point, don't call me to help you out; I am not interested"!
If you're not interested in helping, what was the point of replying to the
message! If you feel so strongly about the issue, how about developing a
constructive argument as to the evidence you have which supports your
limited point of view.
DUNCAN S. SMITH
------------------------------
Date: Fri, 27 Feb 1998 11:09:09 -0000
From: "Nick Roadnight Main Account"
Subject: Re: Environmental Policy
With respect to what I am sure is the vast knowledge and experience of 'J.
Orser' (his original message text is at the end of this message), I have to
disagree with his sentiment.
Whilst I agree with his core intention of developing a "...unique policy
statement..." that leads to a "...meaningful EMS...", I disagree with his
sentiment that reviewing the work of others is "...having a "lipservice"
EMS...".
To reinforce this, I would like to ask the question of 'J. Orser', and all
others who feel this way,
"How did you develop your core knowledge of environmental systems etc?"
Did you not learn from others?
Did you not seek others advice?
Did you not attend courses that were based on known best practice at that
time?
I know that I did!
Our role, as Professional Consultants (and we are Professionals) in the
process, is to help organisations solve their problems as effectively and
efficiently as possible.
We are able to do this because we have a vast amount of experience, gained
in many businesses, and across many sectors.
Our shelves are filled with reference materials, which in my case includes
the environmental manuals for some 220 (or there abouts) companies that our
organisation has worked for. It also includes approximately 650 reference
books and reports on EMAS, ISO14001, BS7750 and other related environmental
issues.
Our organisation is overflowing with experienced consultants in the area,
and our contact database is stuffed with people who I can call when I see
something unusual.
Our success is based upon using all of this resource to help our clients.
What is wrong with them doing all of this themselves?
OK, the process will be longer. The chance of first time success will be
lessened, and the efficiency of their systems may be lower. But they are
only doing what we do in the normal course of our business.
As a Professional Consultant, I believe that you should abide by this
principle.
Finally, you state "...don't call me to help you out; I am not
interested...".
Well, I do not think that you will have many problems achieving this
objective!!
Regards,
Nick
.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.
Businesses that take professional advice consistently out-perform those that
don't.....
Nick Roadnight
Tellus Limited
Lyster Court
Millfield
Plymouth
PL1 3JB
UK
Tel +44 (0) 1752 207007
Fax +44 (0) 1752 207008
Email nroadnight@intelligence.co.uk
.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.o0O0o.
A brief word about us follows:
Employing ten full time Consultants and supported by 30 Associates, we
provide a range of Management Consultancy services to clients around the
world, including:
Organisational strategy and planning
Marketing strategy, planning and implementation
Operations management
Human resource management and development
Industrial relations
IT strategy, planning and implementation
Organisational improvement (ISO9000, TQM, BPR etc.)
Environmental management (ISO14000, EMAS etc)
Project management
.o0O0o.o0O0o.o0O0o.o0O0o.ORIGINAL MESSAGE TEXT.o0O0o.o0O0o.o0O0o.o0O0o.
- -----Original Message-----
From: J. Orser
To: iso14000@quality.org
Date: 26 February 1998 23:59
Subject: Re: Environmental Policy
>I consider it very important for the management of a firm to sit down and
>development their own unique policy statement, rather than copy from
another
>company. If the firm is serious about forming a meaningful EMS, some time
>should be given to this important first step. However, if you are only
>interested in having a "lipservice" EMS, a "book-shelf" EMS, then by all
>means, copy away. Just one point, don't call me to help you out; I am not
>interested.
>___________
>Business Address
>Orser Environmental & Safety Inc.
>195 King St., Suite 204, St. Catharines, Ontario, Canada L2R 3J6
>(905) 688-0500 Fax 688-4746, jorser@niagara.com, E&OE
>Sent from residence.
------------------------------
Date: Fri, 27 Feb 1998 09:25:51 -0500 (EST)
From: jorser@niagara.com (J. Orser)
Subject: Re: Environmental Policy
I posted this message to get a response; I am not disappointed.
>>I consider it very important for the management of a firm to sit down and
>>development their own unique policy statement, rather than copy from
>another company. If the firm is serious about forming a meaningful EMS,
some >>time should be given to this important first step. However, if you
are only
>>interested in having a "lipservice" EMS, a "book-shelf" EMS, then by all
>>means, copy away. Just one point, don't call me to help you out; I am not
>>interested.
In response, Nick Roadnight wrote:
>With respect to what I am sure is the vast knowledge and experience of 'J.
>Orser' (his original message text is at the end of this message), I have to
>disagree with his sentiment.
>Whilst I agree with his core intention of developing a "...unique policy
>statement..." that leads to a "...meaningful EMS...", I disagree with his
>sentiment that reviewing the work of others is "...having a "lipservice"
>EMS...".
"Reviewing" the work of others is not "lipservice" and the word I used was
"copy". Surely a verbatim copy of another firms' policy hanging in the
reception area is not desirable.
>To reinforce this, I would like to ask the question of 'J. Orser', and all
>others who feel this way,
>"How did you develop your core knowledge of environmental systems etc?"
>Did you not learn from others?
>Did you not seek others advice?
>Did you not attend courses that were based on known best practice at that
>time?
>I know that I did!
So have I. I have yet to copy. Every company is different and that is one
of the joys of this work.
>Finally, you state "...don't call me to help you out; I am not
>interested...".
>Well, I do not think that you will have many problems achieving this
>objective!!
I have all the work I can handle, thanks very much. Believe it or not, some
firms really want an honest approach. The ones that don't ask me back are
the ones who wanted to skimp or tried to dictate the result, regardless of
the truth.
My apologies to the list for taking up space in this manner.
___________
John Orser, OHST, ROHT
*****Orser Environmental & Safety Inc.*****14000 International*****
195 King St., Suite 204, St. Catharines, Ontario, Canada L2R 3J6
(905) 688-0500 Fax 688-4746, jorser@niagara.com, E&OE
------------------------------
Date: Fri, 27 Feb 1998 09:24:45 -0500
From: "Connie G. Ritzert"
Subject: RE: Policy
Any long-term participants in this list will recognize me as vehemently
against copycat approaches to developing an EMS ( we had a long discussion
on templates several weeks ago). However . . . in the case of
environmental policy statements, it has been my experience that examining
those of other organizations can be very useful in helping management
translate the intent and concepts of such a "policy" into more concrete
terms.
The word "policy" itself is frequently used somewhat indiscriminately for a
variety of statements, positions, procedures, guidance documents, etc.
within some organizations. While the ISO 14001 requirement on policy may
seem simple, experience says it is not. In many cases, organizations
struggle with the concept and the semantics. Reviewing examples of policy
statements ( "good" and "bad") provides an opportunity to learn more about
the possibilities and pitfalls in constructing such a statement. Since the
EMS rests firmly on the environmental policy, and in fact, its purpose is
to implement that policy, the more learning one can do before finalizing
the policy statement, the more likely that statement will say what is
actually intended and be effective.
That is a long-winded way of saying I think it is a good idea to look at
other organizations' policy statements. One source: company web sites.
Several companies include their environmental policy on their web page,
although frequently it is not easy to find. Try using the search
capability if one is included. Other sources - newsletters such as CEEM's
International Environmental System's Update . That publication has carried
several policy statements over the last couple of years. Another source -
- - ( if you want to take the time to pursue it:)) most major companies will
send you a copy of their environmental policy if you write a letter of
inquiry.
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
------------------------------
Date: Fri, 27 Feb 1998 10:35:28
From: Paul Sinclair Stewart
Subject: re: environmental policy
In the interest of keeping this list a forum for dealing with the massive
learning curve we all face, and in keeping with ISO's own policy of their
standards being "constantly under review", I must take exception with the
reply below to a well-meaning request for a less time-consuming access (on
the internet, I assume) to already-accepted applications. I can only assume
the sender was having a bad day.
> if you are only interested in having a "lipservice" EMS, a "book-shelf"
EMS, >then by all means, copy away. Just one point, don't call me to help
you out; >I am not interested.
>Orser Environmental & Safety Inc.
>195 King St., Suite 204, St. Catharines, Ontario, Canada L2R 3J6
>(905) 688-0500 Fax 688-4746, jorser@niagara.com, E&OE
As a research scientist, as well as an environmental consultant, I daily
thank the Powers That Be for all available information in electronic form.
We would be stale meat in the academic, private and gov't research world if
we had to reinvent all previous research wheels every time we wanted to
take another baby step ahead. I will re-ask the question for the benefit of
the previous mailer, as well as the group as a whole:
Could any persons aware of a database (and yes, I know how to use search
engines) on- or off-line, of complete or work-in-progress applications for
certification (by sector if possible), please share it with the group?
I know this is asking a lot, but that's what this kind of technology is
for! ('nuff said, don't mind me...I just can't stand petulance)
********************************************************************
Paul S. Stewart c/o ABIOGEN ENVIRONMENTAL SERVICES
Marshfield Manse, RR #3 Charlottetown,
Prince Edward Island, CANADA C1A 7J7
Tel: (902) 566-4078 email: abiogen@isn.net
"If you're not part of the solution, you're part of the precipitate"
*********************************************************************
********************************************************************
Paul S. Stewart c/o ABIOGEN ENVIRONMENTAL SERVICES
Marshfield Manse, RR #3 Charlottetown,
Prince Edward Island, CANADA C1A 7J7
Tel: (902) 566-4078 email: abiogen@isn.net
"If you're not part of the solution, you're part of the precipitate"
*********************************************************************
------------------------------
Date: Fri, 27 Feb 1998 09:43:32 -0500
From: Stan Carson
Subject: re: environmental policy
This site has links to environmental policies for a number of companies.
http://www.trst.com/iso3.htm
At 10:35 AM 27/02/1998, you wrote:
>In the interest of keeping this list a forum for dealing with the massive
>learning curve we all face, and in keeping with ISO's own policy of their
>standards being "constantly under review", I must take exception with the
>reply below to a well-meaning request for a less time-consuming access (on
>the internet, I assume) to already-accepted applications. I can only assume
>the sender was having a bad day.
>
>> if you are only interested in having a "lipservice" EMS, a "book-shelf"
>EMS, >then by all means, copy away. Just one point, don't call me to help
>you out; >I am not interested.
>>Orser Environmental & Safety Inc.
>>195 King St., Suite 204, St. Catharines, Ontario, Canada L2R 3J6
>>(905) 688-0500 Fax 688-4746, jorser@niagara.com, E&OE
>
>As a research scientist, as well as an environmental consultant, I daily
>thank the Powers That Be for all available information in electronic form.
>We would be stale meat in the academic, private and gov't research world if
>we had to reinvent all previous research wheels every time we wanted to
>take another baby step ahead. I will re-ask the question for the benefit of
>the previous mailer, as well as the group as a whole:
>
>Could any persons aware of a database (and yes, I know how to use search
>engines) on- or off-line, of complete or work-in-progress applications for
>certification (by sector if possible), please share it with the group?
>
>I know this is asking a lot, but that's what this kind of technology is
>for! ('nuff said, don't mind me...I just can't stand petulance)
>
>
>
>********************************************************************
>Paul S. Stewart c/o ABIOGEN ENVIRONMENTAL SERVICES
>Marshfield Manse, RR #3 Charlottetown,
>Prince Edward Island, CANADA C1A 7J7
>Tel: (902) 566-4078 email: abiogen@isn.net
>"If you're not part of the solution, you're part of the precipitate"
>*********************************************************************
>
>
>********************************************************************
>Paul S. Stewart c/o ABIOGEN ENVIRONMENTAL SERVICES
>Marshfield Manse, RR #3 Charlottetown,
>Prince Edward Island, CANADA C1A 7J7
>Tel: (902) 566-4078 email: abiogen@isn.net
>"If you're not part of the solution, you're part of the precipitate"
>*********************************************************************
>
------------------------------
Date: Fri, 27 Feb 1998 10:38:10 -0500
From: "Robert Clifford, Jr."
Subject: re: Environmental Policy
I'll weigh my vote in favor of reviewing other environmental policies.
Yes, we all know it's common industry practice to benchmark other processes
- -- and I include policy development as such a process. The issue, after
you've shown your client examples of these policies, is getting them to
delve deeply into their own corporate character and pull out a statement
that is both functional and meaningful.
However, Mr.Orser's frank comments should serve as a welcome reminder that
the commodity" - approach to environmental management systems lurks out
there, and will increasingly be a problem for the integrity of our practice
should ISO 14001 become recognized as a standard-of-care in industry or
should some major supply-chain or government mandate arise ("... just gimme
one of them ISO programs, and make it pronto, I've got a DOE / GM / Chinese
government proposal to write !!) After all, there are consultants out
there who advertise that they will write a policy statement within 2 weeks
of client engagement (presumably, you do a global search on the name "Acme"
and replace it with your own). And, regretably, I'm sure they're
responding to a real demand for that type of thing.
Robert Clifford
ISO Environmental Consultancy
clifford@quality.org
------------------------------
Date: Fri, 27 Feb 1998 08:30:56 -0800
From: "Bert P. Krages"
Subject: Re: Environmental Policy
Several corporate environmental websites are linked to the following page:
. I don't know for certain
that they contain environmental policies but I would be surprised if none
of them did. Also, they may provide e-mail addresses of contacts that
could send you copies.
One recommendation I have for large organization is to prepare two policy
statements. The first should briefly state the organization's principles
with regard to the environment such as compliance with the law, etc. This
statement, which should be less than one page, communicates the gist of the
organization's policies and is more likely to be read than a statement that
is several pages long. Also, the conciseness makes it more useful for
communicating to the public.
The second policy statement, which should be oriented towards employees,
sets forth in more detail the obligations of employees such as planning to
avoid environmental problems, procedures for reporting environmental
concerns, organizational resources to assist in compliance, and a very
general description of the consequences associated with failure to abide by
the policy. This policy can also deal with the some of the more difficult
ethical issues likely to be faced by facilities (i.e., do we shut down
production if a pollution control device fails). This policy statement can
also be made publicly available but because of its content it is not useful
as a sound bite. It should also be incorporated into employee training
programs.
Also note that organizations in the United States will probably want to
conform to the federal government's guidelines for corporate compliance
programs which requires some elements not encompassed by ISO 14001
(discipline and detection of misconduct). The benefits of such conformance
are more deferential treatment with respect to enforcement actions and
lighter sentences if convicted of a criminal offense. These elements are
not difficult to add in the ISO context and can provide additional legal
protection for organizations and their managers.
At 12:13 PM 2/26/98 -0700, Chris watson wrote:
>I have recently had a number of requests for copies of Environmental Policy
>(EP) statements produced by organizations that are currently
>registered/certified to ISO 14001.
>
>Are any listserve members aware of a relatively less time intensive method
>to obtain these documents than requesting them directly from the
organizations?
>
>By way of explanation ............. I am sure we all recognize the potential
>benefits (good examples of EPs that met the requirements, etc.) and pitfalls
>(copying something that does not reflect your organizations specific intent
>and needs, etc.) of modelling your EP statement on the current "accepted"
>EPs. However, I believe, that organizations are looking for some guidance
>on the overall structure and language of the EP statements since the
>requirements for content are (relatively) well defined in Section 4.2 of ISO
>14001.
>Chris D. Watson P.Geol, CEA
>Environmental Coordinator
>Quality Certification Bureau Inc.
>
>(403) 217-1610 (Phone)
>(403) 217-1585 (Fax)
>
>
Bert P. Krages II
Environmental Law and Mediation
900 S.W. Fifth Avenue, Suite 1900
Portland, Oregon 97204
Law:
Mediation:
------------------------------
Date: Fri, 27 Feb 1998 11:13:52 -0600
From: Phil Rooney
Subject: Re: Environmental Policy
I believe the intent of the original message was not to deny or
denigrate the practice of looking up references and using existing
resources to create useful and meaningful EMS policies.
I believe the intent was to decry a practice in which some might engage
that is not far removed from photocopying an existing EMS policy,
whiting out the existing company name, and typing in the new company
name. (More tragic to pay someone huge fees to do this for you.)
Anyone want to defend THAT practice?
Phil Rooney
LLCHD
Lincoln, NE
------------------------------
Date: Fri, 27 Feb 1998 18:29:33 +0100
From: "Goodman, Sally"
Subject: Environmental Policies
Hello everyone,
I can restrain myself no further, despite intending not to join in this
particular debate.
There have been numerous excellent replies, mainly from consultants, so
I thought I would add a viewpoint from another angle.
>From a certification point of view, an auditor hopes to see a policy
which not only meets the basic requirements of the standard, but also
has real meaning and enables anyone, especially the employees but also
Joe Public, to fully appreciate the environmental direction taken by the
company. Please don't take this comment to mean that we audit against
any additional requirements. We don't (which is why I say "hopes" and
not "expects"). But there are ways of writing a policy which meets the
minimum requirements, and ways of writing a policy which meets the
minimum requirements but then adds value and becomes a living, useable
and useful document. Most people writing a policy statement for the
first time can use a little help and direction - we are all human. It
can be very difficult to sit down with a blank sheet of paper and write
something from scratch. Being able to review a few policies which have
met the requirements of the standard can be very helpful at the
implementation stage, to give an impression of the various styles that
can be used and the type of content which may be acceptable.
However, I fully endorse all the other comments which have said that
there is no substitute for then writing a policy which is unique to your
company and its culture. After all, the first requirement of 4.2 is
that the policy "is appropriate to the nature, scale and environmental
impacts of its activities, products and services". Too many times I
have seen a policy which could equally well have applied to a nuclear
disposal facility or to the local car wash. If some basic research into
other policies has been done, hopefully this type of situation can be
avoided. It does, however, depend on the consistent approach of
certification bodies so that inappropriate policies do not get
certification.
Nuff said.
Regards to all,
Sally
Sally L Goodman
Product Manager, Accredited Environmental Systems Certification
DTP 325 Section for Certification
Det Norske Veritas
Tel: +47 67 57 8213
Fax: +47 67 57 9705
Email: sally.goodman@dnv.com
http://www.dnv.com
------------------------------
Date: Fri, 27 Feb 1998 15:20:52 -0500
From: Diana Baldi
Subject: Re: Environmental Policy
To Bert Krages:
Watch out for the multiple policy approach. I have seen companies have
longer versions intended for environmental specialists or for public image
then have shorter versions communicated to employees for 14001
implementation. Actually I have seen three or four policies that are
slightly different posted,on employee business card-size card, in policy
awareness training and on web sites. All of them claiming they are the
environmental policy. This is a problem of mixed messages to employees as
well as a document control nonconformance. The (singular) policy should be
useful to the business and meet the specific requirements of 14001.
To Sally Goodman:
I agree with your points, but have been disappointed by some third party
auditors in the nonconformances written for the env. policy clause. For
example--requiring the client:
a) to have a separate "environmental policy" (not allowing for an
integrated management policy or adoption of a global policy at the site)
b) state that it is the framework for setting objectives ( rather than
allowing the specific commitments to be the framework)
c) state that it is available to the public IN the policy
d) state exactly "prevention of pollution" . These types of
nonconformances deter a company from writing a meaningful policy.
I have also been disappointed by companies that put together a string of
words that meet 14001 (minimally) but gives no clue as to the type of
company writing it.
It is useful to review policies from other companies to see the vast
differences in style and content and to identify things that you like or
dislike so that you can design one meaningful to your company's objectives
and internal cultures.
------------------------------
Date: Fri, 27 Feb 1998 09:08:14 -0500
From: JAMORTER@auto.rockwell.com
Subject: Re: Environmental Policy
Subject: Environmental Policy
Author: Chris watson at @Internet
Date: 26/2/98 12:13 PM
I have recently had a number of requests for copies of Environmental
Policy (EP) statements produced by organizations that are currently
registered/certified to ISO 14001.
Are any listserve members aware of a relatively less time intensive
method
to obtain these documents than requesting them directly from the
organizations?
By way of explanation ............. I am sure we all recognize the
potential benefits (good examples of EPs that met the requirements,
etc.) and pitfalls (copying something that does not reflect your
organizations specific intent and needs, etc.) of modelling your EP
statement on the current "accepted" EPs. However, I believe, that
organizations are looking for some guidance on the overall structure
and language of the EP statements since the requirements for content
are (relatively) well defined in Section 4.2 of ISO 14001.
Chris D. Watson P.Geol, CEA
Environmental Coordinator
Quality Certification Bureau Inc.
(403) 217-1610 (Phone)
(403) 217-1585 (Fax)
______________________________ Reply Separator ___________________
In my country this standard is very new for that reason to develop a
EP is also new so I believe that some times is important for us to
take a look of another EP's not for copy them just to have an idea
about how to develop one according to company goals and at the same
time make it as simple as possible
Juan Mortera
jamorter@meritorauto.com
Suppliers Quality Assurance
Meritor LVS (SLP)
San Luis Potos, Mexico
------------------------------
Date: Mon, 02 Mar 1998 01:19:52 +0800
From: Benny
Subject: [B] Re: Problems of getting ISO14000 for a group of Co.
Hi all,
Re: Problems of getting ISO14000 for a group of Co.
I'd sent this mail once but I cannot get any reply. I am not sure it's
lost or no reply.
Anyway, this queation is very important to my company and the common
question
for small companies. I am so appreciate to get any suggestions.
My plant consists of 6 companies. Their business is not the same but
they are under the
same GROUP, ie. they are the sub-company of a holding company. However,
some sub-company have other workplace in another place.
I know that ISO14000 is registered for a location or a plant not a
company and it's
one of the difference between ISO9000. I think the reason is that if the
plant get fire,
staff of other company in the same plant should know how to do.
My reason is that if I register for ISO14000, what I should apply for
certification is
the holding company or the separate companies.
If I get the certification of holding company, can I put the "ISO14000"
in the publication
or name card of the sub-companies?
Thanks for anybody help
Benny Lam
------------------------------
Date: Sun, 1 Mar 1998 20:32:36 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: re: This week at QUALITY.ORG
Notice:
The QUALITY.ORG "Book of the Week" this week may be of particular interest
to the members of this ISO14000 list:
Moving Beyond Environmental Compliance:
A Handbook for Integrating Pollution Prevention With ISO 14000 ~
by Thomas E. Welch, Tom Welch (1997)
The link to it is: http://www.quality.org/BOW.htm
Thanks.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
- -----------------------------------------------------------------------------
Visit our Online Quality Resources Website and Bookstore at
http://www.quality.org
=============================================================================
------------------------------
Date: Mon, 2 Mar 1998 10:32:08 +0800
From: susan-hong.li@cniab.mail.abb.com
Subject: Handbook
Dear all,
I would appreciate if someone could send A Handbook for integrating
pollution prevention with ISO14000~ to me by E-mail because I cannot access
http://www.quality.org/Bow.htm. Thank you in advance.
I am looking forward to hearing from you.
Kind Regards,
Susan
My E-mail address,
susan-hong.li@cniab.mail.abb.com
------------------------------
Date: Mon, 2 Mar 1998 09:50:55 +0100
From: "Goodman, Sally"
Subject: RE: Environmental Policy & non-conformities
Dear Diana,
Thank you for your comments. I was interested and concerned to read the
examples of non-conformities raised against environmental policy by some
registrar auditors. These are all examples of what should not be
happening. To take each on in turn:
a) There is no requirement to have a separate environmental policy. An
auditor should be assessing the policy, in whatever form it is, which
may be a stand-alone environmental policy, or may be an integrated
policy containing environmental elements, to see if it conforms to the
requirements of ISO 14001. If there are clear areas where the policy
does not meet the specific requirements of the standard, the auditor
should raise an accurate non-conformity against the appropriate clause
of the standard. Let's be clear about this - certification auditors
cannot require the company to write its policy in a particular way.
Adoption of a global policy at a site can be OK, provided that there is
some indication of how it is "apropriate to the nature ............of
its activities...." If the global, or corporate, policy is adopted, the
company needs to go through it in detail, to see how it applies to them
and to see if there any any additional site- or company-specific issues
which need to be addressed in addition. Again, if the global policy
(accompanied by any additional statements) meets the requirements of the
standard, and it is clear that it has not been adopted without thought,
there should be no problem.
b)Providing a "framework for objectives" is a harder element against
which to identify non-conformities. However, the auditor should not
insist that the company repeats the words of the standard in the policy.
It can be OK to include the objectives, it can be OK to describe in
summary the procedure by which the objectives are defined, in fact there
are many ways in which this particular clause can be satisfied.
Sometimes it is clear that there is a link between the activities of the
company, its policy and commitments (or objectives) and sometimes it is
very difficult to see how the policy provides a framework.
c) There is absolutely no requirement to state in the policy that it
is publicly available (although some companies choose to do this). The
auditor must ask how the policy is made available to the public and
identify the objective evidence in this regard. The minimum is usually
taken to be that the policy must be available to anyone upon request and
that a copy of the policy is kept in the main reception area. I have
heard of some registrar auditors who insist that the company goes beyond
this minimum, but that is the perogative of the company. It is, of
course, good practice if the company is more pro-active in communicating
its policy, but that it a matter for the company, not the certification
auditor.
d) Sure, the company can meet the requirements of the standard by
including the words "prevention of pollution" in the policy. However,
as you rightly say, the policy will be more meaningful if some more
substance and thought is apparent in this regard.
Just a note of caution - each audit situation is unique and, whilst
general rules can be set up, the certification auditor must use his or
her professional skill and judgement in deciding what consititutes
conformance to the standard. Another problem is that non-conformity
notes are often not written in a clear, accurate and understandable way.
It is so important that the client clearly understands the nature of
any non-conformities, so that they can address the root cause of the
problem. A good non-conformity note will clearly identify the exact
element or sub-element of the standard against which there is a
non-conformance (i.e. the requirement), describe the failing in clear,
unambiguous terms and give specific examples of the objective evidence
to support the non-conformity.
With kind regards,
Sally
Sally L Goodman
Product Manager, Accredited Environmental Systems Certification
DTP 325 Section for Certification
Det Norske Veritas
Tel: +47 67 57 8213
Fax: +47 67 57 9705
Email: sally.goodman@dnv.com
http://www.dnv.com
>-----Original Message-----
>From: Diana Baldi [SMTP:Baldifamily@compuserve.com]
>Sent: Friday, February 27, 1998 8:21 PM
>To: Bert P. Krages; [unknown]; Chris watson
>Subject: Re: Environmental Policy
>
>I agree with your points, but have been disappointed by some third party
>auditors in the nonconformances written for the env. policy clause. For
>example--requiring the client:
>a) to have a separate "environmental policy" (not allowing for an
>integrated management policy or adoption of a global policy at the site)
>b) state that it is the framework for setting objectives ( rather than
>allowing the specific commitments to be the framework)
>c) state that it is available to the public IN the policy
>d) state exactly "prevention of pollution" . These types of
>nonconformances deter a company from writing a meaningful policy.
>
>
------------------------------
Date: Mon, 2 Mar 1998 17:47:02 +0100
From: "Goodman, Sally"
Subject: RE: [B] Re: Problems of getting ISO14000 for a group of Co.
Hi Benny,
I don't recall seeing your message first time round, so maybe it got
lost somehow.
Firstly, ISO 14001 is applicable to any organisation, whether it is an
individual site, or a company, or a large company which consists of many
smaller companies. It is EMAS which is currently limited to a
individual site.
It sounds like you have two choices for the situation you describe.
You may either apply for ISO 14001 for each individual business, in
which case each company will be audited and will (hopefully) receive a
certificate. At the end of this process, most certification bodies
would I am fairly sure, be able offer the option of an "umbrella"
certificate for the group, once all the individual businesses had been
audited.
Or you may apply for ISO 14001 for the Group. This assumes that there
is one EMS covering all the companies owned by the holding company. If,
however, as you describe, the businesses of the companies within your
group are different, they will all have to be audited, because they will
all have different activities, be located within different local
environments and have different significant environmental aspects.
If there are other companies in the same plant, which are not related to
your company, or if they are not operating under the same EMS, it will
be necessary for you to recognise and manage the environmental
interfaces between the companies which are in the same plant. In
effect, the significant activities of another company on the same site
becomes a significant indirect aspect for you. Also, if there are any
shared facilities, such as effluent treatment or disposal, power
generation, waste storage, etc., you will need to ensure that these are
acknowledged and managed in some way within your EMS.
Whether or not you can put "ISO 14001" in publications or name cards of
the companies may depend on the condiitons of the accreditation scheme
under which you obtain your certification, so I would recommend checking
this with your certification body.
I hope this helps. If any of this is not clear, please contact me
again.
With kind regards,
Sally L Goodman
Product Manager, Accredited Environmental Systems Certification
DTP 325 Section for Certification
Det Norske Veritas
Tel: +47 67 57 8213
Fax: +47 67 57 9705
Email: sally.goodman@dnv.com
http://www.dnv.com
>-----Original Message-----
>From: Benny [SMTP:kebenny@hkstar.com]
>Sent: Sunday, March 01, 1998 5:20 PM
>To: iso14000@quality.org
>Subject: [B] Re: Problems of getting ISO14000 for a group of Co.
>
>Hi all,
>
> Re: Problems of getting ISO14000 for a group of Co.
>
>I'd sent this mail once but I cannot get any reply. I am not sure it's
>lost or no reply.
>Anyway, this queation is very important to my company and the common
>question
>for small companies. I am so appreciate to get any suggestions.
>
>My plant consists of 6 companies. Their business is not the same but
>they are under the
>same GROUP, ie. they are the sub-company of a holding company. However,
>some sub-company have other workplace in another place.
>
>I know that ISO14000 is registered for a location or a plant not a
>company and it's
>one of the difference between ISO9000. I think the reason is that if the
>plant get fire,
>staff of other company in the same plant should know how to do.
>
>My reason is that if I register for ISO14000, what I should apply for
>certification is
>the holding company or the separate companies.
>
>If I get the certification of holding company, can I put the "ISO14000"
>in the publication
>or name card of the sub-companies?
>
>Thanks for anybody help
>
>Benny Lam
------------------------------
Date: Mon, 02 Mar 1998 10:18:43 -0700
From: Chris Watson
Subject: Environmental Policies
Thanks to everyone who has responded to the request for Environmental Policy
information so far - and especially to Sally for capturing the full intent
behind my original request.
As the environmental program leader for a registrar (QCB Inc., based in
Western Canada) it is not uncommon to receive a large amount of requests
from clients and potential clients regarding sources of information to help
them come to grips with the application of ISO 14001. However, as an
environmental and quality systems auditor I have also seen too many
organizations that are looking to "fast-track" the application of various
standards without due consideration of the ramifications.
Our organization, and I'm sure that most, if not all, registrars, caution
clients to take on as much ownership of the implementation as possible,
since that is where a large number of benefits will occur.
Getting back to the original request, however, can anyone else provide some
direction on finding Environmental Policies that have been accepted as
meeting the requirements of ISO 14001?
Chris D. Watson P.Geol, CEA
Environmental Coordinator
Quality Certification Bureau Inc.
(403) 217-1610 (Phone)
(403) 217-1585 (Fax)
------------------------------
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