17 Common Issues in ISO14001 Certification Audits

 

There are some common issues in ISO14001 environmental system certification. We have compiled 17 points that are frequently encountered during ISO14001 certification within system certification companies. Let's take a look together!

 

1. Environmental protection documents during factory construction

1) Environmental Impact Report (Form) for construction projects — assessment report provided by qualified evaluation agencies

2) Approval of Environmental Impact Report — approval from the Environmental Protection Bureau

3) "Three Simultaneities" acceptance of environmental protection for construction projects — acceptance by the Environmental Protection Bureau

4) Fire safety acceptance report — acceptance by the fire department

 

2. Identification, evaluation, and updating of environmental factors

1) Incomplete identification of environmental factors, mainly including the following situations:

a. Failure to fully identify according to the scope of production and operation processes, for example: the scope of production and operation includes sales, but environmental factors in the sales process were not identified;

b. Failure to identify according to the sequence of the production process flow; identification of environmental factors lacks order, which easily leads to omissions;

c. Failure to consider past occurrences and planned future factors, for example: the company plans to expand a new factory, but environmental factors during the expansion process were not identified;

d. Failure to fully consider the product lifecycle in identification, such as material selection during product design and recycling/disposal after product scrapping.

 

2) Unreasonable evaluation of environmental factors, with deviations in determining important environmental factors.

 

3) Environmental factors not updated in a timely manner, such as:

a. Changes in product production processes, but environmental factors were not re-identified or updated;

b. Changes in product materials, but environmental factors were not re-identified or updated in time;

c. Changes in national, local laws, regulations, and other requirements, but environmental factors were not re-identified or updated in time;

d. Factory relocation to a new site, but environmental factors were not re-identified or updated in a timely manner.

 

3. Control planning for important environmental factors

1) Failure to determine control methods/procedures for all important environmental factors;

2) Control requirements for important environmental factors have not been formalized into corresponding regulations, such as procedural documents, operation documents, or other methods.

 

4. Identification and review of laws, regulations, and other requirements

1) Insufficient identification of laws, regulations, and other requirements, especially local regulations and customer requirements not properly identified;

2) No applicability review conducted for relevant laws, regulations, and other requirements, failing to identify specific applicable clauses within laws, regulations, and other requirements;

3) Laws, regulations, and other requirements not distributed to relevant departments and personnel;

4) Failure to update laws, regulations, and other requirements in a timely manner; revised, updated, or repealed laws, regulations, and other requirements were not re-identified, collected, or reviewed promptly.

 

5. Environmental objectives, indicators, and management plans

1) Failure to fully consider important environmental factors when setting environmental objectives;

2) No specific indicators set for established environmental objectives; some indicators are not measurable;

3) Failure to develop corresponding management plans for all objectives and indicators; management plans have unclear responsibilities, unclear start and end dates, and lack budget;

4) Failure to adjust or revise management plans in a timely manner based on implementation status, such as when the company has relocated or environmental standards have changed without revising the management plans.

 

6. Organization, responsibilities, authorities, and resources

1) Environmental management requirements are missing in the responsibilities and authorities of various positions;

2) No competency requirements specified for key positions (e.g., lab technicians, mechanics, cleaners, warehouse staff, operators, etc.);

3) Insufficient investment in environmental protection facilities, for example, daily production of 120 tons of wastewater but the treatment station capacity is only 80 tons per day.

 

7. Competence, training, and awareness (human resource management)

1) Insufficient staffing or inadequate competence for key positions, for example, operators at the wastewater treatment station only know how to use pH test strips for acidity testing and lack ability for other tests;

2) Insufficient environmental awareness training for all employees, or training exists but lacks post-training assessment and evaluation of training effectiveness;

3) Personnel are unclear about important environmental factors related to their positions and unfamiliar with control methods for these factors.

 

8. Information exchange

1) Information exchange requirements for important environmental factors are not specified;

2) No channels established for external information exchange, for example, when external stakeholders (community residents, etc.) have complaints about the company, there is no publicly available complaint phone number, mailbox, or other methods;

3) Complaints and grievances from external stakeholders are not recorded, not handled timely, and no timely feedback is given to the stakeholders after handling;

4) Lack of information exchange among internal stakeholders, such as internal publicity, lectures, meetings, etc.

 

9. Document control

1) Documents are not distributed to specific positions, especially key positions;

2) The suitability of documents is not reviewed or updated in a timely manner, for example, when laws and regulations change but related documents are not reviewed or updated accordingly;

3) Document formats are inappropriate, for example, MSDS materials are in English but on-site operators have insufficient English comprehension.

 

10. Operational control

1) Operational control procedures do not clearly specify the standards to be followed, such as which national or local standards, time periods, or levels apply in wastewater/noise/exhaust gas control procedures;

2) Operational control requirements are not communicated to suppliers, such as chemical suppliers, engineering subcontractors, etc.;

3) Major deficiencies exist in on-site environmental operational control:

a. Waste classification is not clearly defined, implementation is inadequate, resulting in mixing of recyclable, non-recyclable, or hazardous waste;

b. Pollution caused by mechanical oil leakage on site was not cleaned up or corrected in time;

c. Environmental protection facilities failed to provide evidence of maintenance;

d. Environmental protection facilities are not operating properly, such as the workshop exhaust gas extraction system not running, or running but the purification pool at the exhaust outlet has no water;

e. MSDS information is not available at the site of chemical use and storage;

f. Positions generating dust and debris (such as grinding, sawing, planing, lathe processes) do not collect dust and debris, causing it to spread everywhere and not cleaned up in time;

g. Flammable and explosive materials are mixed with other flammable substances, and hazardous materials are not stored in separate spaces;

h. Incomplete dosing records at the sewage treatment station, unable to track dosing time and dosage;

i. No records of handover and transfer of waste oil, waste liquid, and other hazardous waste, and no hazardous waste treatment consignment note for final disposal (hazardous waste must be handled by qualified institutions, issuing a unified treatment consignment note during disposal).

 

11. Emergency Preparedness and Response

1) Failure to develop emergency plans for potential significant environmental aspects, usually including fire emergency plans, chemical spill/explosion emergency plans, environmental protection facility failure emergency plans, and natural disaster emergency plans;

2) Emergency plans/preplans have been developed but corresponding training and drills have not been conducted;

3) Emergency drills have been conducted, but the effectiveness of the drills and emergency procedures have not been evaluated;

4) After executing emergency plans or drills, emergency procedures have not been reviewed or revised in a timely manner.

 

12. Monitoring and Measurement

1) Insufficient planning for monitoring and measurement, failing to determine the items to be monitored and measured, methods to be used, and monitoring frequency;

2) Failure to monitor and measure the implementation status of objectives, targets, and management programs;

3) Unable to provide monitoring records of daily operational management processes;

4) Failure to conduct regular monitoring of noise, exhaust gas/dust, and wastewater, which should be done at least once a year, generally entrusted to local environmental monitoring stations or other qualified environmental monitoring agencies;

5) Owned monitoring equipment is not regularly calibrated or verified, such as noise testers and wastewater testing equipment;

6) The sewage treatment station cannot provide records of sewage monitoring and testing, or monitoring exists but the frequency does not meet the requirements specified in documents.

 

13. Compliance Evaluation

1) No "Compliance Evaluation Control Procedure" has been established;

2) Unable to provide evidence of compliance evaluation, at least once a year;

3) Compliance evaluation has been conducted on the implementation of environmental laws and regulations, but not on other requirements;

4) Compliance evaluation does not cover all applicable laws, regulations, and other requirements.

 

14. Nonconformities, Corrective Actions, and Preventive Actions

1) Environmental nonconformities are not handled (corrected) in a timely manner when they occur;

2) Failure to identify the timing for taking corrective and preventive actions;

3) Causes of nonconformities are not analyzed, corrective actions are not properly implemented, failing to prevent recurrence;

4) Causes of potential nonconformities are not analyzed, preventive actions are inappropriate, failing to prevent occurrence;

5) The effectiveness of corrective and preventive actions is not evaluated.

 

15. Internal Audit

1) Annual internal audits are not planned, such as not specified in documents or no annual internal audit plan formed;

2) Audit contents listed in the internal audit plan do not cover all audit scopes;

3) Internal audit team member arrangements lack impartiality, with audits of their own departments;

4) The internal audit plan clearly requires audit contents, but checklists have missing clauses;

5) Internal audit nonconformity reports are formed, but cause analysis is inadequate, corrective actions are not targeted to causes, lacking specificity;

6) The effectiveness of corrective actions taken for internal audit nonconformities is not verified or evaluated;

7) Internal audit reports are not formed;

8) Internal audit reports exist, but evaluations of system operation only reflect nonconformities and deficiencies, without evaluating achieved environmental performance.

 

16. Record Control

1) Records are not retrievable, no list, catalog, or other retrieval methods;

2) Retention periods for records are not specified, and records are not kept according to retention requirements;

3) Records are improperly stored, resulting in loss or damage.

 

17. Management Review

1) Management review plans have incomplete review contents, such as missing reviews of environmental performance, follow-up results of previous management reviews, developments and changes in laws, regulations, and other requirements related to organizational environmental factors;

2) Insufficient input information for management review, lacking relevant materials/evidence;

3) Management review outputs do not include decisions and actions related to modifications of environmental policies, objectives, and other environmental management system elements;

4) Management review reports do not reflect the evaluation results of the system's suitability, adequacy, and effectiveness;

5) Management review resolutions do not clarify responsibilities, division of labor, or time limits;

6) No records exist for the implementation status of management review follow-up actions, and no effectiveness verification.