| Company V makes mechanical parts with about a hundred working people.
Two yeas ago the company gained the certification of integrated system
of ISO9001: 2000 and ISO14001:1996. Last month the company received
the transition assessment of ISO14001:2004. At that time the assessor
Mr. A pointed out the following meaningless item which might be caused
by low competence of the assessor.
1. The assessorfs comment
Your company does the periodic evaluation of compliance with applicable
legal requirements by internal audits held twice a year. And records
of the internal audits on the subject are ones of the period evaluations.
I donft agree with this way, because it burdens excessive responsibility
of the evaluations on auditors, and there are such as twelve applicable
legal items in your company that it may be difficult to check compliance
with all items for auditors.
The evaluations should be done by the manager of the department
which is responsible for compliance with applicable legal requirements.
I suggest that the manager of responsible section who has responsibility
of compliance with applicable legal requirements has to evaluate compliance
also using some checklists. The checklist will be the right records
what the Standard requires.
According to the 2004 revision of ISO14001, my certification body
places emphasis on evaluation of compliance with applicable legal
requirements. Your companyfs way may not be adequate for the certification
bodyfs policy.
2. The companyfs countermeasure
We totally do not agree with the assessorfs alternative for the way
of the evaluation of compliance by following reasons.
(1) The assessorfs immature confusion nonconformity and
comments
The assessor says gI do not agree ------gfor comments like for nonconformity.
There is no gshallh such as that evaluation of compliance with applicable
legal requirements shall not be done by internal audits, evaluation
of compliance with applicable legal requirements shall be done by
the person who has responsibility of the compliance and the records
shall be checklist.
(2) The assessorfs comments are bad alternatives
The reasons are as follows.
@The assessorfs confusion gcomplianceh with gits evaluationh
To be in compliance with applicable legal requirements is day-to-day
work, not periodic.
To evaluate compliance with applicable legal requirements is another
work and the evaluation should be done objectively. To ensure objectivity
and impartiality of the evaluation, it is not preferable that the
persons who are responsible for the compliance evaluate their own
work.
AThe difficulty to check twelve applicable legal items
is not true
The assessorfs saying of gdifficultyh for something may easily make
confusing, because the degree of gdifficultyh is not described measurably.
The assessor should have said how many hours it takes for the evaluation.
We think it is not gdifficulth for auditors, because it takes about
thirty minutes at the longest.
BThe emphasis on evaluation of compliance with applicable
legal requirements does not mean to install heavy documentation.
It is clear from the fact that 2004 version deletes the requirements
of a documented procedure for periodically evaluating compliance with
relevant environmental legislation and regulations from 1996 version. |