Fourteen drums, one sentence from a supervisor
During the site tour at a food-processing plant, the auditor sees 14 unlabelled 200-litre drums behind the effluent plant. The shift supervisor says they are "empty and rinsed, waiting for the contractor". There is a strong solvent smell and liquid visible in the base of two drums. The contractor's last collection note is dated seven months earlier. The EMS procedure requires drums to be labelled with contents and hazard, stored on bunded pallets, and removed within 30 days. When asked for the waste inventory the supervisor says the environmental coordinator "keeps all that at head office". The audit is due to end in three hours and the coordinator is unavailable until after the closing meeting. Three of the 20 waste transfer notes you have already sampled are unsigned by the receiving facility.
1. Assess the evidential value of what you have seen and been told. What would you need before writing a finding?
Read the worked answer
Separate the three kinds of evidence.
- Direct observation (strong): 14 drums, no labels, liquid in two drums, solvent odour, off-bund or unverified storage. This is first-hand and can be recorded as observed fact (time, location, condition). It does not depend on anyone's statement.
- Statement by the supervisor (weak alone): "empty and rinsed" is an assertion by an interested party, unverified, and contradicted by the odour and liquid. Under 19011 clause 6.4, information from interviews should be corroborated. Treat it as a lead to test, not as evidence.
- Records (medium, needs authentication): collection note dated seven months ago supports failure to remove within 30 days, provided you confirm it is the most recent one and that no other contractor was used.
Before writing the finding:
- Confirm the procedural requirement exists and read its exact wording (label content, 30 days, bunding).
- Check whether these are waste at all (e.g. incoming raw material drums) - ask the supervisor what the drums originally contained and cross-check with purchase records if time allows.
- Look for any labels fallen off, any inventory list on the drums, any contractor schedule.
- Extend the sample: any other drum storage on site; the other 20 transfer notes; the waste contractor's registration and the receiving facility's authorisation.
- Record what you could not verify, and why.
A finding is defensible when it rests on observed conditions plus a documented requirement, not on a manager's explanation.
2. The three unsigned transfer notes and the drums point to different clauses. Formulate the finding(s), choose the classification, and justify it.
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Possible findings:
- 8.1 operational control: waste is not stored and labelled as required by the organisation's own procedure; unlabelled containers of unknown content on site beyond the 30-day limit. Evidence: observation + procedure + collection date.
- 7.5.3 control of documented information / 8.1: waste transfer notes unsigned by the receiving facility - records not completed as required, and possibly indicating the organisation cannot demonstrate lawful transfer (a compliance obligation under 6.1.3 and evaluated under 9.1.2).
- 9.1.2 may be implicated if the organisation has never detected this in its own compliance evaluation.
Classification reasoning. Ask: is the requirement implemented at all, and what is the risk?
- 14 drums, unlabelled, containing liquid residues, adjacent to the effluent plant - a direct pollution pathway to drain/ground, plus a likely breach of waste duty-of-care obligations. Combined with 3/20 unsigned transfer notes (15% of sample), the failure looks like a breakdown of control, not one careless container.
- That combination justifies major on 8.1, with the unsigned notes as supporting evidence or a separate minor, depending on whether the practice is systemic. If further sampling shows the drums issue is a one-off housekeeping lapse and all other notes are signed, a minor is defensible for the drums and the notes should not be inflated.
- Do not merge unrelated clauses into one finding to make it look bigger, and do not split one systemic failure into five minors to make it look smaller.
3. You have three hours, no access to the coordinator, and a closing meeting to run. What do you do?
Read the worked answer
1. Use the time for verification, not for writing. Extend the transfer-note sample to a defined number, inspect other waste storage points, and interview one more person who handles waste (e.g. the supervisor's team member, the contractor's driver if present).
2. Ask for the missing evidence through a defined route. Request that the coordinator's waste inventory and contractor records be made available, and offer a short extension or a documented evidence submission immediately after the audit. Note whether the client agreed.
3. Present findings accurately at the closing meeting. State the observed conditions and the requirement breached; distinguish clearly between what was verified and what remains unverified, and say so. Present the unsigned notes as a sampled result (3 of 20) and note that the sample was limited by time.
4. Record the limitation. The absence of the process owner is an audit limitation affecting coverage of 8.1 and 9.1.2; it belongs in the report and should inform the team's conclusion, not be quietly absorbed.
5. Do not soften a major to avoid an awkward meeting, and do not raise a major on the strength of a supervisor's remark. If the evidence supports a major, say so with the evidence; if it does not yet, say what is needed to close the question.
6. Escalate if needed. The lead auditor decides, and the CB's decision-maker must see the finding and the limitation.