5468_14001pitfalls_0206.qxd 5/6/06 9:36 AM Page 38
THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
This compliance confirmation is an essential part of the EMS - in
MONITORING AND MEASUREMENT a19 OR ✘ COMMENT/PLAN
practice the legal and other requirements need to be reviewed
Procedure in place to define:
and a decision taken on how to check compliance and how often
a73 the measurement to be taken,
to do this.
a73 calibration (if relevant)
a73 tracking of objectives and targets
A sound process needs to be produced and records must be
a73 periodic evaluation of compliance
with identified environmental
produced and kept to show the process was effective.
legislation?
This can be done by addition to audits - but ensure the evidence
All instruments used to measure is clear and well documented. You can also do ‘stand-alone’ legal
EMS-related criteria are subject to
compliance audits - or use other methods which meet the
calibration control?
Calibration procedures ensure that:
requirements.
a73 calibration frequency is stated and
reviewed?
COMMON PITFALLS
a73 methods of calibration are defined and
Compliance stated to be checked at internal audit - but no
traceable to national standards?
evidence in the records of the audits.
a73 calibration status is clear?
a73 records are kept of calibration
Compliance check does not cover all applicable legislation and
certificates and of which
instrument was used for each test?
other environmental requirements.
Records of compliance with identified
legislation are held?
Frequency of legal compliance evaluation 4.5.3 NON-CONFORMITY, CORRECTIVE ACTION & PREVENTIVE ACTION
is stated and kept to?
When things go wrong you need first to recognise that fact, to
find out why they went wrong, and then to address the cause of
the problem and its effects. This process of learning from
4.5.2 EVALUATION OF COMPLIANCE mistakes is a real benefit of any management system.
4.5.2.1
KEY REQUIREMENTS
a73 Identification, evaluation and investigation of
a73 Organisation shall establish, implement & maintain a
non-conformance
procedure for periodically evaluating compliance with
a73 Implementation of corrective and preventive actions
applicable legal requirements.
There are arguments over whether ‘disposition’ refers to ‘location’
a73 And keep records of the results of these evaluations.
or ‘disposal’ of records, but whichever definition you prefer there
4.5.2.2
is a clear need to know where records are held, and to make sure
your disposal mechanism is as well thought through as your
a73 Organisation shall evaluate compliance with other
storage method.
requirements to which it subscribes.
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