Ecolabel and the Environmental Management System

Is the certification auditor doing an audit to look for findings or nonconformities against the elements of the standard? Is there an additional scope that is frequently missed out as the auditor busily works to assess conformance or otherwise? The Ecolabel standard for products provides that agenda.

These thoughts were swirling around as a 3-day audit against ISO 14001:2015 was being conducted at a multi-site consultancy organisation which was largely focused on reducing its carbon footprint as well as ensuring that waste streams were adequately managed. These significant aspects had been at the forefront of the management system efforts to improve its environmental performance, though it has to be said that these efforts had become diluted over time. Segregate paper, cardboard, plastic tins and glass was hardly cutting a dash with the highly educated workforce and it was time for a makeover – or at least new ideas were needed to reinvigorate the system.

As the transition to ISO 14001:2015 was taking place at this audit, the elements relating to context, interested party requirements, leadership and risks and opportunities were reviewed and found to conform to the new standard. The review of progress towards life-cycle perspective provided a window of opportunity to breath new life into the management system using an Ecolabel as an example.

The example I pushed related to the use of cleaning chemicals used by the third-party cleaning teams on a daily basis. There had not been any recognition that this issue was particularly interesting and indeed as previously the COSHH implications had predominated and this had previously been addressed.

A quick search on the internet revealed that a new Ecolabel amendment for detergents and office cleaning chemicals had been issued in June 2017 and a new breed of chemicals that were devoid of microplastics had been specified. The organisation had not considered that their vast expanse of office space across 6 sites could be using products that damage the environment. Legal they may be, but the use of detergents, rest room cleaners, paper towels and even toilet paper could have a significant impact which had not been noticed.

The observation raised to the company will help focus minds and allow environmental co-ordinators to develop a really meaningful debate about the wider use of cleaning chemicals in their offices. The Ecolabel product changes cover the following topics;-

• microplastics are to be banned from products; removal of the derogation for fragrances classified chronic category 3 (H412);
• stricter requirements on preservatives that allow only a sufficient dose to preserve the product;  bio-based products must be sourced from sustainable plantations with certification required for palm oil, palm kernel oil and their derivatives;
• packaging using 80% recycled materials is exempt from all other packaging requirements.

For the manufacturers who have made the significant effort to create these newer office cleaning products, surely their efforts should be of interest to companies who actually have ISO 14001:2015 certificates on their walls and letter headings?

In this day and age of mature management systems, it is the auditor’s role to promote new thinking as a way of improving environmental performance, rather than just hunting round for findings that have decreasing risk and increased level of nit-picking associated with them.

6^th December 2017

John Marsden –  B.Sc., M.Sc., M. Phil., FIEMA, IEMA Principal EMS Auditor,

Marsden International (UK) Ltd