“Failure is not an option.” We’ve all heard this colloquial quote uttered in one form or another at some point in our lives. However, is failure even a possible outcome as it pertains to an ISO 14001 Environmental Management System (EMS) Audit? The short answer is no. A common misconception among companies being audited is that they can fail an audit, leading to their certification being put in jeopardy.
What can occur during an EMS audit is that any number of major or minor "non-conformances" can be found by the auditor, which essentially means that a part, or specific parts, of the organization's Environmental Management System do not meet the requirements outlined in the ISO 14001 standard. This does not mean that a company has "failed the audit". From here, an organization is given ample time to correct the non-conformances, and if the proposed corrective actions are sufficient, certification or recertification will be recommended by the auditor. In fact, non-conformances identified during an EMS Audit may present a major opportunity for companies that thrive on continual improvement.
Although it can be hard to stomach non-conformances found during EMS auditing, very rarely does it mean that your company is in imminent danger of losing its EMS compliance certification. In every instance, if your organization has findings showing non-conformances during an EMS Audit, your audit report will highlight the areas of your EMS process that need to be addressed, as well as include notes and recommendations from your EMS auditor.
The first step to take if your business receives findings during an EMS Audit, would be to prioritize your auditor’s findings based on their critical nature. (i.e. major, minor, advisory, etc.) – by doing so you can focus on the most likely causes for your EMS audit results. Your auditor will provide a comprehensive audit report detailing both major and minor nonconformities if applicable, along with references to the corresponding ISO 14001 clause and detailed objective evidence identified during the audit. Using this information, you can begin to develop your corrective action plans.
Non-conformities – It’s very important that when an organization documents errors and/or non-conformities, there needs to be processes in place for identifying issues and how they can be resolved. An auditor will be looking for evidence of this, and if proper logging/tracking of these issues is not in place or lacking process foundations, then this can heavily contribute to unwanted findings.
Goals – A core component of any strong environmental management system is setting goals related to the framework provided in ISO 14001 standard. These goals can be focused on financial, legal, operational, regulatory, safety, or many other types of improvement. However, not taking the time to map out these goals, or vast underachievement can add to an auditor's findings.
Personnel Loss – Retirements, position changes, or key personnel leaving the company, particularly on the quality management team, can cause gaps in the system. If not reassigned or newly responsible parties made clear, these changes can lead to big errors or oversights.
Internal Auditing – Continual improvement (within ISO 14001) calls for maintaining a consistent practice of reviewing your businesses own systems and procedures. There are a few different ways that a company can accomplish this, one way is by reaching out to a Certification Body that is not affiliated with your certification provider, and that offers 1st-Party (Internal) Audits. Another option is to have your quality team conduct the internal audit, using the ISO 14001 standard and internal auditing resources to guide their tasks. Skipping the internal review process can be a sure-fire way to major or minor non-conformanity
Training Issues – Proper skills and a vast knowledge base are foundational pillars for the employees of a successful business. If your company has not thought out, documented, and implemented training procedures and requirements for your organization, this can lead to errors, inefficiencies, and unexpected results. Ultimately, a lack of formal structured training can hurt your company’s chances.
Management Review – Something that we do here internally, management review delves into the details of each process within a business and occurs semi-regularly throughout a given timeframe to make sure everything and everyone is functioning as it/they should. During an EMS audit, your auditor will want to see a minute’s log kept during these meetings to validate their occurrences. If management reviews aren’t taking place with your EMS stakeholders consistently at your company, aren’t being logged, or not taking place at all, this can contribute to a disappointing outcome.
Changes to the ISO 14001 Standard – Although not frequent, ISO eventually revises and updates its standards. When this happens, ISO 14001 certified organizations have 3 years to transition and meet the requirements of the updated version of the standard. If this is put off, there is confusion on the changes, or the EMS fails to support the updates, then non-conformances will likely be found.
Going back to the beginning of this article, it’s important to remember that if your company were to be cited with major non-conformances during an EMS audit, it’s not the end of the world. Your organization will be given the audit report with all the findings, and given time to take, and make, corrective actions to all the major/minor non-conformances or issues that were found.
Once the corrections have been completed, you must submit evidence of the changes – this often comes in the form of documentation or documented policy changes – assuming that the evidence provided your auditor meets the criteria laid out in the standard, then certification or recertification will still be achieved.
Contact Smither’s about EMS auditing services today!
