ISO14001:2015 Management System Guidance and Transition ... · This checklist is being provided to...

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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