Given the fact that the Carbon Reduction Commitment started this April and the speed at which the impending deadline for registration (September 30th), it seems to be a perfect time to consider how the ISO 14001 auditor community could add value to the organisation that may be implicated.
The first point is that this scheme is potentially complex and the certification auditor should certainly invest in some study time to become acquainted with the basics. I am working my way through the 99 page CRC User Guide (6th April Update) which provides an excellent reference source to the scheme. The auditor must then understand a number of definitions that have an immediate impact on the registration process. This includes terms such as the half hourly meter, the qualification period (the calendar year of 2008), the registration period (April to September 2010) and the making of an information disclosure during the registration period.
The auditor should find out if the responsible person within the organisation is tracking the CRC. Has it been included within the EMS legal register? By now it should be up there in lights because the scheme has been gathering momentum since early 2009. Has the responsible manager registered for full participation or made an information disclosure? Either way, the quantity of electricity that flowed through all half-hourly meters during 2008 should have been compiled. If it is more than 6000 megawatt hours, then full participation is required. This information gathering process should be checked by the auditor. Have all domestic accommodation supplies been deducted – important to universities? Have franchisors and landlord/tenant relationships been clarified? The list goes on!
The auditor should also check that the organisational structure of the business or undertaking is fully understood and the guidance of the financial director may have played a crucial role in determining this. Public sector entities and universities, schools and government departments are all potentially implicated within CRC so EMS auditors working within these sectors should check that the specific rules are understood.
A recent ISO 14001 audit of an engineering company which is part of a large group provided an interesting insight into CRC. The HSE manager was very well aware of the scheme, though an interesting line of enquiry was investigated to determine potential exemption on the basis of a Climate Change Agreement negotiated through the relevant trade body. The certification body auditor should always be exploring such avenues of opportunity, even though they may need further investigation and discussion.
On a final note, my personal ‘auditor journey’ to reduce carbon dioxide emissions as described in the July article is progressing extremely well. There is a growing number of consultants and ISO 14001 auditor personnel who are using the simple but effective Excel spreadsheet developed specifically for the purpose – join our group by emailing me. Since 1st June, I have saved 247 kg of carbon dioxide with much more to follow!