5468_14001pitfalls_0206.qxd 5/6/06 9:36 AM Page 32
THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
COMMON PITFALLS
DOCUMENT CONTROL a19 OR ✘ COMMENT/PLAN
a73 There should be a clear link between Significant Aspects
Procedure in place to define mechanism
for document control?
and operational control procedures. In fact every identified
Significant Aspect must be linked to an operational control
Procedure includes:
or an Objective and Target (and sometimes both).
a73 Authority for approval
a73 Occasionally there are Significant Aspects which are not
a73 List of holders of documents to
ensure they are available to those
linked to either Objectives or Operational Controls. An
who need them
example might be a Policy commitment to reduce energy
a73 Master list to show current status
consumption, which is not supported by processes to effect
a73 Means of making and recording changes
a73 Disposal of obsolete copies
the reduction. The task of the auditor is not only to establish
a73 Retention of file copy of
whether procedures are adequate, but also to identify
superseded documents
when procedures may be missing altogether.
a73 Review of documents
a73 Requirements to date documents
a73 It is quite common to find important detail missing from
procedures, eg a waste management procedure should
include all of the detail which is needed to deliver
compliance with the duty of care including the
4.4.6 OPERATIONAL CONTROL
possession and review of licences, marking and control
of waste, the documents to be raised and the people
The mechanisms in ISO 14001 for managing processes which are
responsible for actions. If this is not sufficiently
related to the organisation’s impact on the environment are operational
detailed then the internal audit may not be effective in
control procedures. These are the detailed instructions for processes,
ensuring compliance.
eg waste management, energy management, storage of chemicals. a73 Bunding (secondary containment to catch leaks) of tanks
is frequently an issue within an EMS. It is quite common
Most significant aspects will be subject to management by an
to find bunds which are ineffective due to leaks, holes or
operational control procedure. (Many of these procedures may already
open valves. If bunds are present there should be a
exist as part of Quality or Health and Safety systems.)
management procedure to make sure that they function
KEY REQUIREMENTS
for their intended purpose, which is secondary containment
and preventionof pollution.
a73 Identify activities associated with Significant Aspects
(including maintenance) and plan them to ensure they
a73 Another area of operation control which is frequently
are carried out under controlled conditions
found lacking is in the management of liquid chemicals.
Often there are no firm procedures for receiving, storing,
a73 Establish and maintain procedures where their absence
dispensing and transporting chemicals. If they happen to
would lead to deviations from Policy, Objectives and Targets
be flammable there are other issues to consider, eg
a73 Stipulate operating criteria in procedures
potential for fire in the storage and distribution process,
a73 Establish and maintain procedures relating to Significant measures to prevent this, and relevant emergency
Aspects of purchased goods and services procedures.
a73 Communicate relevant procedures and requirements to
suppliers and contractors
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