Compliance Obligations – new term for EMS practitioners

COMPLIANCE OBLIGATIONS

As part of my personal views on the almost developed ISO 14001:2015, these blogs provide an auditors’ perspective of what the new standard and it’s elements may mean for anyone associated with management systems.

The phrase “compliance obligations” is a tidy expression for legal requirements that apply to an organisation, together with “everything else” that had been tagged onto the back of the law. In today’s society, these “other requirements” have risen in importance, as organisations see the need to make declarations of intent and direction. Following a particular initiative that is relevant to the industry associated with the company is a common theme, but it has never really been made mandatory. Now that compliance obligations have become a feature of ISO 14001 2015, there will be much greater emphasis on these voluntary statements of intent.

“Oh yes, you decided to follow the British Plastic Federations initiative to reduce the amount of plastic pellets reaching the world’s oceans – that’s commendable” may be the response of a certification auditor to a declaration. But as that is an add-on, the auditor may be quite unlikely to follow any audit trail to see if they are actually doing anything about it. Like managing their raw material silos and the delivery tanker to ensure that every last granule of plastic is properly transferred to the silo and not into the surface water drain.

Now, the need to wrap everything up into compliance obligations is real progress in my opinion. It makes it easier for us auditors to write a nonconformity if the organisation “forgets” to do anything about this commitment – that may be in the environmental policy but which becomes invisible to all.

So, yes, I’m enthusiastic about this phrase. In any case, these voluntary commitments that organsations make about what they are going to do to improve their environmental performance means that they are working together with other companies – this always helps.

I’ve been working with a large resort chain to put ISO 14001 in (along with my 100 days per year of certification audits). This chain has joined the Carbon Management Initiative, which provides a centralised approach to tracking carbon use and reducing it. I applaud the fact that ISO 14001:2015 places this alongside LEGAL requirements, as it is probably likely to lead to better management of carbon and it is totally voluntary. However, once all compliance obligations are locked into the management system, it becomes mandatory and a certificate to ISO 14001 could be at risk if the organisation trivialises this commitment.

That’s why I like this phrase so much!