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ISO14001:2015 Management System Guidance and Transition Audit Checklist
Transition audit for: Company Name: Corner Brook Pulp And Paper Limited Address: 1 Mill Road
P.O. Box 2001
Corner Brook, Newfoundland
CAN, A2H 6J4
Audit Date: Jul 03, 2017 to Jul 03, 2017
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Instructions to the Applicant
This checklist is being provided to SAI Global clients currently certified to ISO 14001:2004 to enable them to self-evaluate the compliance of their Environmental Management System documentation with the NEW requirements of ISO 14001: 2015 (the Standard), in preparation for a scheduled Transition audit. (Please note - The checklist is not intended to be a comprehensive verification of all the requirements of the Standard).
What you need to do:
1. Please assess your management system according to the Standard and complete the checklist in its entirety.
2. Provide this completed checklist in electronic format to your SAI Global auditor prior to your stage 1 audit.
What your auditor will do:
During the audit, your auditor will review the completed checklist by reviewing relevant documents and confirming your results. This checklist becomes part of the transition audit records.
Prior to the Transition Audit
Prior to the SAI Global transition audit you must have audited your entire system against all the requirements of the Standard. As a minimum, all activities, services and products associated with key parts of EMS must have been internally audited and objective evidence maintained of an internal audit program. Your top management will also need to have undertaken a management review to ensure that your system is suitable, adequate and effective for the organisation scope and activities.
The Structure of Your Documentation
The structure of your management system to support the Environmental Management should be unique to your organisation. Information may be in paper or electronic form and procedures can be interpreted in whatever method best suits your organisation’s needs, including flow charts, picture diagrams, video imaging, soft copy computer based procedures etc. The main consideration is that the procedures can be understood and utilised by the appropriate personnel within your organisation, which in turn provides the control and continual improvement that the Standard requires.
The size and scope of your organisation will be key factors in determining the system’s structure. It is the responsibility of the SAI Global auditor to determine compliance with ISO 14001: 2015, regardless of how you have put it together.
Note: Section 3 of ISO 14001: 2015 defines “Terms and definitions” used in the Standard. This may assist you in understanding the terminology used in this document.
Also be aware that a thorough understanding of Annex A and B of ISO 14001 2015 will be important for your business to effectively implement Environmental Management System or upgrade the system form the previous Version of this Standard (ISO/AS 14001 2004)
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BACKGROUND INFORMATION
The purpose of this audit report is to summarise the degree of compliance with relevant criteria, as defined on the cover page of this report, based on the evidence obtained during the audit of your organisation. This audit report considers your organisation’s policies, objectives, and continual improvement processes. Comments may include how suitable the objectives selected by your organisation appear to be in regard to maintaining customer satisfaction levels and providing other benefits with respect to policy and other external and internal needs. We may also comment regarding the measurable progress you have made in reaching these targets for improvement. SAI Global audits are carried out within the requirements of SAI Global procedures that also reflect the requirements and guidance provided in the international standards relating to audit practice such as ISO/IEC 17021, ISO 19011 and other normative criteria. SAI Global Auditors are assigned to audits according to industry, standard or technical competencies appropriate to the organisation being audited. Details of such experience and competency are maintained in our records. In addition to the information contained in this audit report, SAI Global maintains files for each client. These files contain details of organisation size and personnel as well as evidence collected during Stage1 and subsequent audit activities (Documentation Review and Scope) relevant to the application for initial and continuing certification of your organisation. Please take care to advise us of any change that may affect the application/certification or may assist us to keep your contact information up to date, as required by SAI Global Terms and Conditions. This report has been prepared by SAI Global Limited (SAI Global) in respect of a Client's application for assessment by SAI Global. The purpose of the report is to comment upon evidence of the Client's compliance with the standards or other criteria specified. The content of this report applies only to matters, which were evident to SAI Global at the time of the audit within the audit scope. SAI Global does not warrant or otherwise comment upon the suitability of the contents of the report or the certificate for any particular purpose or use. SAI Global accepts no liability whatsoever for consequences to, or actions taken by, third parties as a result of or in reliance upon information contained in this report or certificate. Please note that this report is subject to independent review and approval. Should changes to the outcomes of this report be necessary as a result of the review, a revised report will be issued and will supersede this report.
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Definitions and action required with respect to audit findings
Major Non-conformance:
Based on objective evidence, the absence of, or a significant failure to implement and/or maintain conformance to requirements of the applicable standard. Such issues may raise significant doubt as to the capability of the management system to achieve its intended outputs.
NOTE: The “applicable Standard” is the Standard which SAI Global are issuing certification against, and may be a Product Standard, a management system Standard, a food safety Standard or another set of documented criteria.
Action required: This category of finding requires SAI Global to issue a formal Non-Conformance Report (NCR), to receive and approve the client’s proposed correction and corrective action plans; and formally verify the effective implementation of planned activities. Correction and corrective action plan should be submitted to SAI Global prior to commencement of follow-up activities as required. Follow-up action by SAI Global must ‘close out’ the NCR or reduce it to a lesser category within 90 days for initial certification.
If significant risk issues (e.g. safety, environmental, food safety, product legality/quality, etc.) are detected during an audit these shall be reported immediately to the Client and more immediate or instant correction shall be requested. If this is not agreed and cannot be resolved to the satisfaction of SAI Global, immediate suspension shall be recommended.
In the case of initial certification, failure to close out NCR within the time limits means that the Certification Audit (Stage 2) may be repeated.
Follow-up activities incur additional charges.
Minor Non-conformance:
This category of finding represents either a management system weakness or minor issue that could lead to a Major non-conformance if not addressed. Each Minor Non-conformance should be considered for potential improvement and to further investigate any system weaknesses for possible inclusion in the corrective action program
Action required: This category of finding requires SAI Global to issue a formal Non-Conformance Report (NCR); to receive and approve the client’s proposed correction and corrective action plans; and formally verify the effective implementation of planned activities at the next scheduled audit.
Area of concern: (can only be raised at a gap or stage 1 audit)
Based on objective evidence (or the absence of), this finding represents a failure to implement a requirement of the applicable standard. Such issues may raise significant doubt as to the capability of the management system to achieve its intended outputs.
Action required: This category of finding requires the client to address the issue with corrective action prior to the stage 2 audit. Failure to address the issue will result in Minor Non-conformances or Major Non-conformances being raised at the stage 2 audit and may prevent certification proceeding.
Opportunity for Improvement:
A documented statement, which may identify areas for improvement however shall not make specific recommendation(s).
Action required: The client may develop and implement solutions in order to add value to their operations and management systems. SAI Global is not required to follow-up on this category of audit finding.
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Executive Summary
Consistent with the organization's environmental policy, it appears that the intended outcomes of the
environmental management system:
include does not include enhancement of environmental performance;
include does not include fulfilment of compliance obligations;
include does not include achievement of environmental objectives.
4 Context of the organization
4.1 Understanding the organization and its context
The organization has has not determined external and internal issues that are relevant to its
purpose and that affect its ability to achieve the intended outcome(s) of its environmental management
system. Such issues shall include environmental conditions capable of affecting or being affected by the
organization.
Examples of the determined issues and environmental conditions:
Environmental Aspects include factors identified by Stakeholders
The CSA Sustainable Forest Management [SFM] Plan and its alignment with the ISO standard.
FSC National Boreal Standard and in particular all of the requirements of Principle 6 and Principle
9 (High Conservation Value Forest Assessment [HCVF] Report)
Issues determined through 5-Year Planning Process
Auditor Comments:
Verified:
No significant changes in activities undertaken by the company since last audit.
All indicators reviewed/agreed to by PAC – see SFM Plan PAC meeting minutes
Two FM standards (CSA Z809 & FSC Boreal) list all issues - therefore identified through that
process
FSC HCV report
Voluntary agreements with external stakeholders – annual letter required to confirm compliance
to voluntary agreement – reviewed summary and file of responses
Five year forest management planning process includes public consultation and public input –
verified example in 2017-2012 Zone 3 Plan
Conforms
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4.2 Understanding the needs and expectations of interested parties
The organization:
has has not determined the interested parties that are relevant to the environmental
management system;
has has not determined the relevant needs and expectations (i.e. requirements) of these
interested parties;
has has not determined which of these needs and expectations become compliance
obligations.
Examples of the determined interested parties, their relevant needs and expectations and ones
determined to be compliance obligations:
Interested Parties: Public Advisory Committee (PAC), FSC stakeholders, Agreement/MOU stakeholders
Needs & Expectations: Forest Management Standards FSC and CSA (HCVF Report and SFM Plan.
Compliance Obligations: Compliance to agreements with stakeholders, SFM Plan targets, 5-Year
Planning obligations
Auditor Comments:
Verified:
PAC list of members and other interested parties (SFM Plan App A & B)
PAC meeting minutes
Public consultation summary for 2017-2012 Zone 3 Plan
Voluntary agreements with external stakeholders
Conforms
4.3 Determining the scope of the environmental management system
When determining its scope, the organization:
has has not considered the external and internal issues referred to in 4.1;
has has not considered the compliance obligations referred to in 4.2;
Scope encompasses all issues within the DFA -
The scope is is not available to interested parties.
Environmental Progress Report and SFM plan
Auditor Comments:
Verified:
Available on Kruger website - http://www.cbppl.com/wp-content/uploads/2017/06/EPR-2016_for-
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Mailing-1.pdf
Conforms
4.4 Environmental management system
The organization has has established, implemented, maintained and continually improved its
EMS, including the processes needed and their interactions to achieve its intended outcomes and
enhance its environmental performance.
The organization’s processes and interactions are:
Compliance Inspections
Incident reporting Process
Forest Management Certifications
Quarterly EMS Review
PAC
Auditor comments:
Verified:
Quarterly EMS review minutes and action plans
EMS procedures & work instructions
Completed prework forms and inspection forms
Audit action plans
Conforms
5 Leadership
5.1 Leadership and commitment
Top management [shall demonstrate leadership and commitment with respect to the environmental
management system by]:
has has not taken accountability for the effectiveness of the environmental management
system;
has has not ensured that the environmental policy and environmental objectives are
established and are compatible with the strategic direction and the context of the organization;
has has not ensured the integration of the environmental management system requirements
into the organization’s business processes;
has has not ensured that the resources needed for the environmental management system
are available;
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has has not communicated the importance of effective environmental management and of
conforming to the environmental management system requirements;
has has not ensured that the environmental management system achieves its intended
outcome(s);
has has not directed and supported persons to contribute to the effectiveness of the
environmental management system;
has has not promoted continual improvement;
has has not supported other relevant management roles to demonstrate their leadership as it
applies to their areas of responsibility.
The primary activities conducted by top management to demonstrate leadership and commitment are:
Has in place an Environmental Management Representative
Has a Forest and Environment Policy
Has in place a Quarterly EMS review process
Has incorporated Environmental Compliance inspections into contractor incentive and Staff
incentive programs
Has allocated resources to address audit and inspection findings
Has instituted disciplinary actions for failure of compliance obligations.
Auditor Comments:
Verified
EMS rep in place
Top management awareness, involvement and support
Minutes of Quarterly EMS Management Review Committee Meetings
Current Forestry and Environmental Policy
Compliance inspection reports
Conforms
5.2 Environmental policy
Top management has has not established, implemented and maintained an environmental
policy that … includes commitment(s) to the protection of the environment, including prevention of
pollution and other specific commitments relevant to the context of the organization. NOTE Other
specific commitment(s) to protect the environment can include sustainable resource use, climate change
mitigation and adaptation, and protection of biodiversity and ecosystems.
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Auditor comments:
Verified:
Documented Forest and Environmental Policy dated April 2017 includes commitment to
prevent pollution, continual improvement, meet or exceed legal and other requirements –
additional commitments developed by Kruger e.g. ecologically sound harvesting and
silvicultural techniques
Conforms
6 Planning
6.1 Actions to address risks and opportunities
6.1.1 General
The organization has has not established, implemented and maintained the process(es) needed
to meet the requirements in 6.1.1 to 6.1.4.
When planning for the environmental management system, the organization;
has has not considered the issues referred to in 4.1
has has not considered the requirements referred to in 4.2.
has has not considered the scope of its EMS
and
has has not determined the risks and opportunities related to its environmental aspects
has has not determined the risks and opportunities related to its compliance obligations
has has not determined the risks and opportunities related to its other issues and
requirements identified in 4.1 and 4.2
that need to be addressed to give assurance that the environmental management system can achieve
its intended outcomes; prevent, or reduce, undesired effects, including the potential for external
environmental conditions to affect the organization; achieve continual improvement.
Identified risks:
Non-compliance to standard operating procedures which control 6 Significant Environmental
aspects, Failure of Compliance inspections,
Emergency Response and the Environmental Progress Report score card
Failure to comply with Agreements/MOUs signed with Interested Parties.
Identified opportunities:
Performing beyond legal requirements i.e. utilization, riparian buffers, residual retention
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Contractor incentives linked to environmental performance
Trained workforce
Conforms
Auditor Comments:
In its operations, the company takes into consideration the risks and opportunities related to its
environmental aspects, its obligations of conformity as well as those associated with external
and internal issues.
OFI: 6.1.1 Consider producing a documented and concise summary of the risks and
opportunities associated with the organization’s environmental aspects, compliance obligations,
external and internal issues and needs and expectations from interested parties.
6.1.2 Environmental aspects
Within the defined scope of the environmental management system, the organization has determined
the environmental aspects of its activities, products and services that it can control and those that it can
influence, and their associated environmental impacts, considering not considering a life cycle
perspective;
Identified life cycle based environmental aspects and impacts:
Life cycle is limited to the scope of the activities of harvesting timber and transporting to the mills -
Adherence to COC certifications for PEFC and FSC
Auditor Comments:
Environmental aspects have been determined in the context of the life cycle of the wood products generated by the organization. It begins with forestry activities and services provided by contractors on Company woodlands and ends with delivery of pulpwood to the mill. Ref: Section 4 of EMS / SFM Handbook - Manual # 1. Conforms
6.1.4 Planning action
The organization has has not planned to take actions to address risk and opportunities identified
in 6.1.1.
Actions taken:
Employee and staff Training
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Emergency Response
Compliance Inspections and directives
EMS quarterly reviews and actions
Audits and resulting action plans
Auditor Comments:
Risks and opportunities associated with environmental aspects, obligations of compliance and
other issues and requirements are managed through work instructions, action plans, follow-up
programs and other environmental management programs.
Conforms
6.2 Environmental objectives and planning to achieve them
6.2.1 Environmental objectives
The organization has has not considered its risks and opportunities when establishing
environmental objectives at relevant functions and levels.
Auditor Comments:
Minor NCR
6.2.1 The organization shall improve the demonstration that its environmental objectives have
taken into account risks and opportunities associated with external and internal issues, needs
and expectations of interested parties and obligations of compliance.
Ref: Procedure 6 - Environmental Objectives, and Planning Actions (Programs) 6.2.1, 6.2.2.docx Environmental programs
Note: risks and opportunities are related to environmental aspects (see clause 6.1.2), compliance
obligations (6.1.3) and other issues and requirements identified in clauses 4.1 (external and
internal issues) and 4.2 (needs and expectations of interested parties).
6.2.2 Planning actions to achieve environmental objectives
When planning how to achieve its environmental objectives, the organization has has not
determined what will be done; what resources will be required; who will be responsible; when it will be
completed; how the results will be evaluated, including indicators for monitoring progress toward
achievement of measurable environmental objectives.
Monitoring Plan
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Programs
Auditor Comments:
All human, material and financial resources and responsibilities required, as well as timelines and follow-
up methods to monitor the progress to achieve the objectives are identified and documented.
Ref:
Procedure 6 - Environmental Objectives, and Planning Actions (Programs) 6.2.1, 6.2.2.docx
Environmental programs
Conforms
7.4 Communication
7.4.1 General
The organization has has not established, implemented and maintained process(es) for internal
and external communications relevant to the environmental management system, including: on what it
will communicate; when to communicate; with whom to communicate; how to communicate.
Forest Management Certification Process
Manual 1, Section 9 Communications
Auditor comments:
Verified:
Manual 1 Section 9 covers procedures for internal and external communications
Communications processes include communications with stakeholders in FM planning
process (see records) and CSA/FSC public participation and communication processes
Viewed External Communications log; Kruger website; SFM Plan June 2017; SFM
Indicator Report 2016
PAC meeting minutes
FMP Planning Zone 3 communications record
Annual Environmental Progress Report
Operations meeting minutes
Conforms
When planning its communications process, the organization has has not taken into account its
compliance obligations; ensured that environmental information communicated is consistent with
information generated within the environmental management system, and is reliable.
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Auditor Comments:
Verified:
SFM Indicator Report 2016
2016 Environmental Progress Report
Supplier letter
Annual list of Agreement Verification letters (Note: this document is not described in the
Communications Procedure – OFI - Consider whether the Annual list of Agreement
Verification letters should be added to the Communications procedure
Conforms
8 Operation
8.1 Operational planning and control
The organization has has not established, implemented, controlled and maintained the
processes needed to meet environmental management system requirements, and to implement the
actions determined in 6.1 and 6.2, by: establishing criteria for the processes; implementing control of the
processes.
The organization has has not controlled planned changes and reviewed the consequences of
unintended changes, taking action to mitigate any adverse effects, as necessary.
Normal and Abnormal activities in the aspects chart and Emergency response associated with each
The organization has has not ensured that outsourced processes are controlled or influenced
and that the type and degree of control and influence has been defined.
Outsourced processes and how they are controlled:
Visitor orientation,
Training requirements for fuel truck drivers delivering fuel to our operations
Permits required by organizations receiving waste oil from our operations (this is an inspection
item on the compliance inspection)
Consistent with a life cycle perspective, the organization:
has has not established controls to ensure that environmental requirements are addressed in
the design and development process for the product or service, considering each life cycle stage;
has has not determined environmental requirements for the procurement of products and
services, as appropriate; Training requirements for fuel truck drivers delivering fuel to our operations
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Permits required by organizations receiving waste oil from our operations (this is an inspection item
on the compliance inspection); Standard Operating Procedures
has has not communicated relevant environmental requirement(s) to external providers,
including contractors; Letters to suppliers
has has not considered the need to provide information about potential significant
environmental impacts associated with the transportation or delivery, use, end-of-life treatment and
final disposal of its products and services. Waste oil disposal; Standard Operating Procedures
Auditor Comments:
Procedure in place - EMS / SFM Handbook - Manual # 1, 12 - Operational Planning and Control 8.1.docx, Version No: 1, May 8, 2017 and Manual 6, Section 2.0, Environmental Work Instructions. Each work instruction is documented. Woodlands Operations Staff is responsible to communicate the Environmental Policy, significant environmental aspects (SEA’s), objectives and targets, relevant Standard Operating Procedures (SOPs), FMOM’s and Environmental Work Instructions to contractors through regular site visits, at operations meetings, and when conducting compliance inspections. The organization provides environmental information (8.1d) to the paper mill under the form of their FSC and CSA forest management certificates, in response to the environmental specifications required by the mill. Conforms
9 Performance evaluation
9.1 Monitoring, measurement, analysis and evaluation
9.1.1 General
The organization:
has has not determined what needs to be monitored and measured; Monitoring Plan; CSA
Indicator targets
has has not determined the methods for monitoring, measurement, analysis and evaluation,
as applicable, to ensure valid results;
has has not determined the criteria against which the organization will evaluate its
environmental performance, and appropriate indicators; SFM indicators and SEA’s; Environmental
Protection Guidelines; Compliance obligations
has has not determined when the monitoring and measuring shall be performed; Monitoring
Plan; Monitoring, Measurement, Analysis and Evaluation Procedure
has has not determined when the results from monitoring and measurement shall be
analysed and evaluated. Quarterly Review
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The organization has has not evaluated its environmental performance and the effectiveness of
the environmental management system. Quarterly Reviews
Auditor Comments:
The organization uses a number of criteria (ref: no.2 inspection) to evaluate its environmental
performance.
Ref: 14 - Monitoring, Measurement, Analysis and Evaluation, version 1, May 8, 2017
2016 Environmental progress report
Conforms
9.3 Management review
The management review:
has has not included consideration of changes in external and internal issues relevant to the
EMS; Refer to EMS quarterly review Agenda and Minutes, 11. New and Emerging Environmental
Issues of Relevance
has has not included consideration of changes in the needs and expectations of interested
parties; Refer to EMS quarterly review Agenda and Minutes, 12. Concerns of Interested Parties;
Meetings with parties during 5-Year Planning Process, and annually thereafter.
has has not included consideration of changes in risks and opportunities Refer to EMS
quarterly review Agenda and Minutes, 16. Commitments to Continual Improvement
has has not included consideration of information on the organization’s environmental
performance, including trends in: nonconformities and corrective actions; monitoring and
measurement results; conformity to its compliance obligations; audit results; Refer to EMS quarterly
review Agenda and Minutes
Auditor Comments:
Verified:
Standing Agenda for Management Review of EMS/SFM System
Minutes of EMS Management Review Committee – Q3 2016; Q4 2016; Q1 2017; Q2 2017 –
item 12 covers “Concerns of Interested Parties”; risks and opportunities to be discussed
as they arise; Item
EMS Weekly Report discussion items
Incident reporting trends 2008 – current; audit results; indicator review; compliance
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inspection reports; agreements review
Conforms
The outputs of the management review:
has has not included … opportunities to improve integration of the EMS with other business
processes, if needed;
has has not included … any implications for the strategic direction of the organization;
Auditor Comments:
Verified:
Minutes of EMS Management Review Committee – table of action items appended to
minutes – includes responsible persons and target dates
OFI – Consider describing the outputs from management review in the Management
Review procedure (Manual #1 Section 18) in more detail as per the description in the ISO
14001: 2015 Standard
Conforms
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Recommendation
The results of this audit indicate that the management system does not fully meet the
requirements of the ISO 14001:2015 standard based on the area of non-conformance identified
during the audit and as documented in the attached Non-conformance Report. As discussed
during the Closing meeting, please submit a response Root Cause Analysis within the next 30
days and completed corrective action plan for minor non-conformances within the next 6
months. A recommendation for certification to ISO 14001:2015 to the scope identified in this
report is on hold pending the receipt, review and acceptance of the corrective action taken.
Audit recommendations are always subject to ratification by the SAI Global certification authority.
This Report was prepared by: Rod Seabrook