5468_14001pitfalls_0206.qxd 5/6/06 9:36 AM Page 18
THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
a73 They examine your aspects identification process to test
whether your EMS has identified these as ‘significant’.
SIGNIFICANCE EVALUATION a19 or ✘ COMMENT/PLAN
(No, they are not infallible, but there needs to be a form
Process is described in sufficient
detail to ensure it is repeatable using
of validation of your results.)
people of similar competence?
a73 They test your results against your process to see that
Criteria for significance are clear,
they are consistent and that no highly significant giving examples if necessary to aid
aspect(s) have escaped the list.
understanding?
They have been applied as described
a73 They look for records to support your process. in procedure?
a73 They look to ensure the process will be repeatable, even Where there is a legal, Policy or other
when carried out by different but equally competent people.
similar requirement the aspect
becomes significant?
COMMON PITFALLS Where there is a lack of data about
a potentially significant aspect the
a73 The system has failed to identify an obviously significant
precautionary approach has been
aspect, eg a high potential for contaminated land on the taken?
site has been ignored.
Views of interested parties have been
taken into account?
a73 Areas of the site or business have not been assessed,
eg suppliers, customer-side impacts, transport, If a risk assessment process has
facilities management.
been used this does not mask the
significance of an aspect?
a73 The process is not repeatable or the reason for an
The answers make sense?
aspect being rated ‘significant’ is not clear.
Links to operational controls,
a73 Scoring systems (if used) do not have sufficient
objectives and legal/other
guidance to be consistent. requirements are clear?
(Good Practice)
a73 Impacts on the environment are not really understood
so are not properly rated.
a73 Good operational controls have ‘masked’ the fact that
they are there to deal with a hazard for the environment
- so a significant impact is rated ‘not significant’.
4.3.2 LEGAL AND OTHER REQUIREMENTS
a73 Records do not really show how the aspects were
This requirement when coupled with the identified significant
identified or rated.
aspects forms the foundation of the EMS. Its intention is to
identify all relevant Legal and other similar requirements which
are applicable to an organisation’s activities, products and services
and to use this data to ensure compliance. In this context ‘compliance’
is related not only to the identified requirements but also to the
organisation’s own Policy.
KEY REQUIREMENTS
The Standard requires that you have a Procedure for gaining
access to relevant legal and related data. There is also a need to
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