ISO 14001:2015 – 9.1.2 Evaluation of compliance – anything new??

I have been asked many times recently has this requirement changed? My answer is that they haven’t changed but the “process” needs to be more clearly and completely defined.

The organization shall establish, implement and maintain the process(es) needed to evaluate fulfilment of its compliance obligations.

Step 1 – define the process. The following items need to be defined:

  • determine the frequency that compliance will be evaluated;
    • This may vary for each type of requirement – regulatory,  customer, community, etc.
      • Regulatory Audits – every 1 to 3 years
      • Customer requirements – PPAP/quality internal audits – annually
      • Other
  • evaluate compliance and take action if needed;
    • How compliance will be evaluated
    • Resources – qualifications of persons doing compliance evaluation
    • How evaluation(s) shall be documented
    • How results will be reported and corrected
  • maintain knowledge and understanding of its compliance status.
    • Reference any inspections that you may do on regular basis – safety, emergency prep, 5S, etc.
    • Reference use of preventative maintenance system to track requirements – SPCC inspections, Air Permit Equipment, Storm Water Inspections, etc.
    • Reference internal audits of work instructions – universal waste, aerosol cans, haz waste, etc.
    • Process to keep current with regulatory changes (see 6.1.3) and how these are reported to management (this should be an input to management review).

The third item is not really new but does require the process be more clearly defined.  There may be some gaps in this area in organizations that don’t do many formal inspections.

Remember it is up to the “organization” (that’s you) to define the process NOT your registration company. So if you have defined the process and implemented it, you CONFORM to the requirements. Your registration company may offer “opportunities for improvement” but these should not be non-conformance’s.

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