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Hi,
Yes, it can be considered as nonconformity. In order to remove it, you need, not only to include it in environmental aspect assessment, but also to determine why it wasn't included.
Here is one article that can help you with conducting corrective action:
- How to proceed once a corrective action is initiated in the EMS https://advisera.com/14001academy/blog/2016/10/24/how-to-proceed-once-a-corrective-action-is-initiated-in-the-ems/
Thank you so much for this. I have more questions, could you please help. The legal register identified some outdated pieces of legislation. Is it a NC?. thank you.
Yes, it is a nonconformity because you need to evaluate compliance at the frequency you defined as appropriate. If the frequency is not appropriate and you do not manage to keep track of the changes, then you need to make changes in the process
Thank you. I thought it would fall under control of documents, 4.4.5 prevent unintended use of obsolete documents.
The standard requires a procedure to identify and have access to the legal requirements, am I right in thinking that the register is not mandatory? Thank you so much.
If we are talking about ISO 14001:2004, you only need to document the procedure. But, since you are required to maintain records about evaluation of compliance with legal requirements, (clause 4.5.2.1) it is recommendable to make such register.
If we are considering ISO 14001:2015, it requires documented information about compliance obligations and that basically means that you need a registry.
For more information about legal compliance, see:
- Demystification of legal requirements in ISO 14001 https://advisera.com/14001academy/blog/2014/10/01/demystification-legal-requirements-iso-14001/
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Dec 28, 2016