We build fans, motors etc in Europe and import to ? Aspects Vs Impacts

Aspect = an environmental aspect is an element of an organization's activities, products, or services that has or may have an impact on the environment.

Impact= An environmental impact is the consequence of the environmental aspect on people, plants or animals.

I am trying to come up with some aspects from the manufacturing of these products and H/O is not very helpful. I understand the difference as above but if I can't see what goes on in the factory how can I know the aspects? I have requested their Aspects/Impacts register to no avail.

 

Why would your head office hold information that will lessen your effort in documenting environmental aspects and impacts associated to your operation? Is their operation different from your site? You mentioned that you know the difference between aspects and impacts but you can't see what goes on a factory. If your site doesn't have factory operations, then you don't need to identify aspects and impacts on factory operations.

 

Hmmmm…….we don't yet have enough information from @QSA5060 Tony. @QSA5060 , it sounds like you are "off site" from the manufacturing you speak of. Please provide some additional information...

1- Is the site you are at also ISO 14001 registered?
2- If you are not at the manufacturing site, what is your role and what have you been tasked with to complete from your remote location?

 

Hi Tony, we import most of our product and do some small assembly here on site. The CB raised a minor non conformance that we had not done a lifestyle perspective and we needed to. This was what he wrote:

"The organisation has not ensured that requirements that can lead to environmental impacts are considered for each stage of the product lifecycle (cradle to grave approach)

a) Determine procurement requirements based on the environmental impacts identified through the lifecycle assessment and communicate the requirements to external suppliers and contractors, including those that carry out the design and development of the products ensuring they have considered each stage of the product lifecycle (cradle to grave approach)

b) Communicate to the customer potential significant environmental impacts associated with transportation/delivery, use, end-of life treatment and final delivery" So they want to see everything from our head office.

 

1- Hi we received our certification before our head office as there is only 1.5 people here in Quality and they have a whole department and bigger operation.

2- we import most of our product and do some small assembly here on site. The CB raised a minor non conformance that we had not done a lifestyle perspective and we needed to. This was what the CB wrote:

"The organisation has not ensured that requirements that can lead to environmental impacts are considered for each stage of the product lifecycle (cradle to grave approach)

a) Determine procurement requirements based on the environmental impacts identified through the lifecycle assessment and communicate the requirements to external suppliers and contractors, including those that carry out the design and development of the products ensuring they have considered each stage of the product lifecycle (cradle to grave approach)

b) Communicate to the customer potential significant environmental impacts associated with transportation/delivery, use, end-of life treatment and final delivery" So they want to see everything from our head office.

 

If your organization only performs assembly, then you are not required to determine the environmental aspects and impacts of the design, raw material acquisition and processing of raw materials into products' activities/processes. The requirement in clause 6.1.2 states that "Within the defined scope...the organization shall determine the environmental aspects of ITS activities, products and services that it can control..." Then the statement after that says: "considering a life cycle perspective". Annex A.3 of ISO 14001:2015 clarifies the concept about the word "consider" that means "it is necessary to think about the topic but it can be excluded". Thus, the auditor raising a nonconformity about not doing a life cycle perspective on the external providers' design and manufacturing activities is invalid and inaccurate.

Even Annex A.6.1.2 clarifies that "When determining environmental aspects, the organization considers a life cycle perspective. This does not require a detailed life cycle assessment; thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient". So just think about the life cycle stages that are applicable to your organization's activities, products and services (e.g. assembly, packaging, delivery, etc.)

The way he wrote the nonconformity statement is also not in accordance with the requirements of ISO/IEC 17021-1:2015 in documenting a nonconformity.