The diesel tank that scores twelve
A galvanising plant with 260 staff has held ISO 14001 certification for six years. Its aspect register scores 62 aspects as likelihood (1–5) multiplied by severity (1–5), with 15 or more treated as significant. A 30,000-litre diesel tank inside a bund scores 12 (likelihood 4, severity 3) and is therefore "not significant", yet the same tank is the first-ranked scenario in the emergency preparedness procedure, and in 2023 a delivery hose failure released about 400 litres, some reaching the surface water drain. The register was last updated in 2021 and contains no reference to a life cycle perspective. The scope statement reads "galvanising, inspection and despatch". The maintenance workshop, which changes oil and stores 200 kg of waste solvent on the same site, is described by the EMS coordinator as "outside the EMS because it is a support function".
1. Evaluate the treatment of the diesel tank against ISO 14001 clause 6.1.2. What finding, if any, would you raise, and how would you decide between major and minor?
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What the standard requires (6.1.2). Within the defined scope the organisation must determine the aspects and associated impacts of activities, products and services that it can control or influence, taking a life cycle perspective, considering normal, abnormal and reasonably foreseeable emergency conditions; define and apply criteria for significance; and maintain documented information on (a) aspects and impacts, (b) the criteria, and (c) the significant aspects.
Where this register fails.
- The tank is a foreseeable emergency condition (and has actually failed), yet the scoring outputs "not significant". A 2023 release of ~400 L to the surface water drain is precisely the severity the criteria are supposed to capture. Severity 3 cannot be reconciled with the tank being the top-ranked spill scenario in the 8.2 procedure - one of the two records must be wrong, and the auditor should establish which by testing the scoring rules with the coordinator (e.g. ask what severity the drain pathway should carry and who applies it).
- The 2021 date plus the absence of any life-cycle element suggests the register no longer reflects the site's actual activities and impacts.
The finding. The criteria exist but are not applied consistently, so a determination required by 6.1.2 is unreliable. That is a nonconformity against 6.1.2, not a mere observation - an observation implies no requirement was breached.
Major or minor. Test the consequence, not the paperwork: does the mis-scoring mean the aspect escapes 8.1 operational controls and 8.2 preparedness? If the bund is inspected, the delivery procedure controlled and the spill kit/response tested, the lapse is a decision error with controls still in place - minor. If the tank has no bund integrity inspection, no delivery supervision and no response equipment, a significant impact pathway is unmanaged and the failure is systemic - major. If you cannot yet tell, extend the sample before classifying.
2. The maintenance workshop is excluded from the EMS. Is that defensible under ISO 14001 clauses 4.3 and 4.4? Explain your reasoning and state the audit action that follows.
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Scope is a technical determination, not a convenience (4.3). The organisation must determine boundaries and applicability based on its context, including external and internal issues, compliance obligations, organisational units, functions and physical boundaries, its activities/products/services, and its authority and ability to exercise control and influence. The scope must be documented and available to interested parties - so it is also a public claim.
Why this exclusion is weak.
- The workshop is on the same physical site, under the same management control, and its oil changes and 200 kg of waste solvent arise from the galvanising activity. Its aspects have direct environmental pathways in common with the in-scope process (drain, waste contractor, storage).
- "Support function" is not a criterion the standard recognises. The test is control/influence and whether the activity's aspects interact with those inside the boundary - not whether the activity is revenue-generating.
- If the work were genuinely performed beyond the organisation's control, 8.1 would require control or influence over the outsourced process, not deletion from scope.
Verdict. A nonconformity against 4.3 and, because the EMS must cover all activities within the boundary (4.4), likely a major: the scope statement underpins the certification decision and is inaccurate to interested parties. Audit action: obtain the documented justification for the boundary, interview the maintenance supervisor directly, verify whether workshop aspects appear anywhere in the register and whether its waste is in the waste inventory, and report to the CB so the certification decision is informed. Do not accept a scope change mid-audit without the CB's authorisation.
3. You suspect both problems are known to the EMS coordinator, who has given you reassuring but vague answers. How do you pursue the evidence without relying on that single source?
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Treat the coordinator as one source among many (ISO 19011 clause 6.4 evidence collection), and triangulate:
- Vertical trace: pick the diesel tank and follow it from 6.1.2 through 6.1.3 (which permit/licence condition and which compliance obligation attaches to the drain?), 8.1 (delivery procedure, bund inspection), 8.2 (spill drill records), 9.1.1/9.1.2 (monitoring and compliance evaluation outputs), and 9.3 (was it on the management review input?). Any break in the chain is evidence in its own right.
- Independent interviews: maintenance supervisor, tanker-delivery competent person, the operator who responded in 2023. Ask open questions about what happened, then corroborate with records.
- Physical verification: bund condition, drain valve position, availability of spill kit, waste storage area.
- Third-party records: waste transfer notes, contractor collections, regulator correspondence, insurer inspection reports.
- Sample the register systematically (all aspects involving bulk liquid storage above a threshold), not only the one you stumbled on.
If access to a source is refused, record the refusal and the reason, report it as a limitation affecting audit conclusions (19011 fair presentation), and factor it into the team's conclusion rather than accepting verbal assurance as evidence.