The Route To ISO 14001:2004 Avoiding Pitfalls

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THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
COMMON PITFALLS 4.5.4 CONTROL OF RECORDS
a73 During a certification audit it is quite common to hear
Records are the evidence that what was planned has actually
about chemical or oil spills, exceeding of the allowed limits
happened. They are a basis for audit, and may well be required
for pollutants and other similar types of non-conformance.
by law.
Third-party auditors then check non-conformance records
to see whether these events have been recorded and
KEY REQUIREMENTS
actioned. Sadly this is not always the case.
a73 Procedure for identifying, maintaining and disposition of records
a73 Failing to recognise an event as a ‘non-conformance’ is a
a73 Records shall be legible, protected, and readily retrievable
common problem.
a73 Retention times to be stated
a73 If it has been recognised and recorded it can then be fed
into the process which investigates the cause, plans the
There are arguments over whether ‘disposition’ refers to
solution and makes sure that the solution is effective,
‘location’ or ‘disposal’ of records, but whichever definition you
including any identified preventive measures.
prefer there is a clear need to know where records are held, and
to make sure your disposal mechanism is as well thought through
a73 Too often companies go from cause to solution without a
thorough investigation. This not only is against the
as your storage method.
requirements of ISO 14001 but also can lead to a repeat of
COMMON PITFALLS
the problem if its true cause has not been identified
and addressed.
a73 On one site the client had had a ‘clear-out’ of old records
before the audit. Unfortunately they were in a skip outside
a73 It is also important that actions are taken and checked
the archive store en route to the land-fill site. These
in a timely manner. On one occasion major problems
records were highly confidential and should have been
were identified by the organisation’s internal audit, and a
subject to secure disposal.
standard time of 6 months was then allowed for correction
of the problems, when 2 weeks would have been
a73 Computer data are often the records relevant to the EMS.
more appropriate.
Occasionally software systems have no back-up or back-up
is stored next to the computer. This would not be
NON-CONFORMANCE CORRECTIVE a19 OR ✘ COMMENT/PLAN considered ‘protected’.
AND PREVENTIVE ACTION
a73 Auditors usually ask to see copies of specific Material
Procedure in place to describe the process
Safety Data Sheets (these would be needed in a hurry in
of non-conformance management including:
the event of a spill). Often they are not available at all, and
a73 Identifying and documenting
occasionally they take so long to appear that any spill
non-conformance
could become a serious incident whilst data is awaited on
a73 Investigating the cause
a73 Proposing and evaluating solution
the preferred method of dealing with it.
a73 Corrective and preventive actions
a73 Records are needed to prove compliance with authorisations
a73 Responsibilities
or consents. Occasionally auditors find that although there
Staff recognise and report non-conformances?
are specified limits in the consent documents there is no
System is functioning as intended
and in a timely manner?
record to prove that they are compliant - this also links to
monitoring and measurement.
Corrective and preventive actions are
documented and effective?
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