A Noncompliance to Government Regulation is Discovered During a Registration Audit

What Happens?

This is one of the most highly debated issues whenever ISO 14001 is discussed. And, as you might imagine, there are few, clear-cut guidelines for auditors. However, there are several general principles that will most likely be followed by registrars.

• The focus of the certification audit is on conformance of the environmental management system. It is not a compliance audit. The audit team will utilize your records; it will not take its own, independent readings of your environmental outputs. Consequently, if your records are correct, current and properly maintained, there is small likelihood that a noncompliance issue will arise.
  
• In the event that your records indicate a clear violation of a regulation or law, and barring any clear-cut guidance (such as from an "Audit Privilege Act"), the audit team may take the following actions: the details of the noncompliance will be reported, in writing, to the executive management of the company; if the noncompliance is of the "reportable" variety, the audit team must inform the client (the management in place at the site being audited is not necessarily the same as the client). As you can see, these issues are not settled - much remains to be resolved. The best course of action is to discuss these issues with your registrar prior to the certification assessment. In this way, there will be no surprises.

It is not yet clear how the conflict between confidentiality agreements between clients and their registrar and the requirements created by law and regulations will be resolved when nonconformities are identified by the audit team. The scenario described may be typical. You are advised to discuss this with your legal counsel and registrar as part of your selection process.

Choose SQA for your ISO 14001 Registrar

The decision to pursue ISO 14001 certification involves a substantial commitment of time and resources. Smithers Quality Assessments recognizes that this is a very personal decision requiring a solution tailored to your needs. To arrange for a SQA representative to review your certification needs, contact us at 330-762-4231 today.