We have received a nonconformance covering Evaluation of Compliance (4.5.2 from ISO 14001). We have a location in Vancouver and have been trying to find a qualified compliance auditor and schedule a compliance audit. Our management review notes from 2013 make mention of the ongoing search. Meeting notes from 2014 also mention that we had not found anyone but were still looking. The compliance audit has not taken place.
Our current procedure for evaluation of compliance states that we will evaluate our different locations “as appropriate”, but Vancouver is a small warehouse and we now feel that a full compliance audit is not necessary (and/or cost prohibitive). We would rather conduct our own review of the various inspection reports each year (fire, sprinkler, etc.) as a way to evaluate compliance. Our Mississauga location, however, is more complex and has had this requirement handled via a contracted compliance audit performed by an outside company.
What is the most efficient way for us to address this nonconformance without conducting a time intensive and expensive compliance audit of our Vancouver location?
Basically, the requirement to conduct a review of compliance at each registered site (per your procedure) is pretty much inescapable. At the end of the day you will need to conduct a review of compliance to legal requirements at the Vancouver site. However, there is NO requirement to contract out this review, meaning that you and/or your team can conduct it internally…both for Vancouver and Mississauga.
The review would include the review of reports you mentioned, but will also be augmented by things like:
- Code requirement for storage heights, aisle widths, etc.
- Waste streams and recycling drains.
- Checking MSDS for products being stored to make sure that all storage requirements are being met.
- Any special handling/storage requirements (for film, etc.).
The reality is that a review has to take place. But…that review does not have to be contracted out and can be completed internally. The time-consuming work is centred around confirming all legal requirements for each location. Once you have a good checklist, conducting the actual review is a fairly straightforward activity.
- Ted Uffen, BRC Consultant