Everything Is Significant: Aspects, Criteria and the Life-Cycle Question
A 180-person bakery runs two gas-fired ovens (1.35 GWh of gas a year) and consumes 2.1 GWh of electricity. It operates an ammonia refrigeration plant with a 380 kg charge, four diesel delivery vans, and uses 52,000 m³ of water a year. Its wastewater, high in BOD and COD, goes to the municipal sewer under a consent with daily limits. It sends 6 tonnes of organic waste a week to landfill or animal feed and uses 40 tonnes of plastic film a year. Its largest customer, a supermarket chain, has told it that from next year it must report product carbon footprint and move to recyclable packaging. The aspect register was built by listing every activity and rating each one 'high', except office paper, which is 'medium'; no criteria are documented. Refrigerant leakage is not listed. Packaging design, supplier selection and end-of-life are not mentioned. The EHS officer says the register is fine because 'we listed everything we do'.
1. Critique the aspect register and describe how to build significance criteria that will actually drive operational control.
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The register fails on purpose. Rating 41 aspects 'high' produces no priority: if everything is significant, nothing is, and the operational controls, monitoring and objectives required by 8.1, 9.1.1 and 6.2 have no focus. Documented criteria are not strictly mandated, but the organisation must establish criteria and apply them consistently, which is unverifiable here.
Specific gaps:
- Emergency and abnormal conditions missing (6.1.2). A 380 kg ammonia charge is a textbook reasonably foreseeable emergency; it belongs in the register even if the plant is maintained by a contractor.
- Life-cycle stages missing. Packaging film, raw material acquisition, transport and end-of-life are not assessed.
- Changes not considered. The customer's recyclability and carbon-footprint requirement is a planned change that alters aspects.
- Compliance obligations not linked. Sewer consent limits and F-gas-type refrigerant rules should be visible drivers.
A workable method: define criteria in two families. Impact criteria - severity (toxicity, persistence, quantity), scale and likelihood, scored on a simple scale. Management criteria - is it regulated, is an interested party concerned, is there cost or business risk. Set thresholds that yield perhaps 8–12 significant aspects, document the scoring for each, and review annually and on change. The register should map activity → aspect → impact → significance → control, so that each significant aspect has a named control and an owner. 'We listed everything' is inventory, not assessment.
2. The bakery argues packaging is the customer's specification and film suppliers' business, so it cannot be responsible. How far does the life-cycle perspective reach, and what must the bakery actually do?
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ISO 14001 does not require a life-cycle assessment and does not make the organisation responsible for its customers' and suppliers' operations. It requires a life-cycle perspective: when determining aspects, consider the stages of raw material acquisition, design, production, transport and delivery, use, end-of-life treatment and final disposal, and consider the extent of control and influence (6.1.2). 8.1 adds that a life-cycle perspective be considered when designing products and processes and in procurement.
So the correct answer is neither 'out of scope' nor 'do a full LCA'. The bakery should:
- Record packaging as an aspect with upstream and downstream stages - film production, printing, transport, and end-of-life - stating the boundary it has chosen and why.
- Assess significance against its criteria. 40 tonnes of film a year with a customer demanding recyclability will likely score high on interested-party concern and regulatory trend, which is a legitimate criterion.
- Act within its influence. Film specification (mono-material instead of laminate), pack format, supplier selection, procurement terms, and the customer conversation itself. These are 8.1 controls, not mandatory redesign.
- Document decisions and limits. Where the customer mandates a non-recyclable format, record the constraint and the influence attempt.
A defensible position is a documented boundary plus real actions in the areas of influence. 'It is the supplier's business' is not defensible once a major customer has made it a condition of trade.
3. The refrigeration contractor states that because they hold the maintenance contract, ammonia is not the bakery's environmental aspect. How should the bakery respond, and which clauses are engaged?
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Control of an aspect is not transferred by a maintenance contract. The refrigeration plant sits on the bakery's site, the ammonia charge is in the bakery's process, and the consequences - evacuation, injury, odour, regulatory reporting - land on the bakery. The contractor's competence is one control among several; it does not remove the aspect from the register.
The bakery should:
- List it under 6.1.2 as an aspect arising from reasonably foreseeable emergency conditions, with significance justified by severity and by interested-party concern (regulator, neighbours, insurer).
- Build the emergency preparedness under 8.2: planned response, trained responders, alarm and detection, drill schedules, and testing of the plan where practicable, with review and revision after tests and after any event.
- Apply operational control under 8.1: leak detection and inspection regime, maintenance schedule, contractor selection and monitoring, spare parts, and the current refrigerant rules that apply to the charge.
- Monitor under 9.1.1: refrigerant purchased and topped up, leak-check records, detection alarms.
- Assess competence under 7.2 for internal responders and for verifying the contractor's competence.
If the bakery wrote 'contractor responsibility' in the register, that entry is the nonconformity, not the justification. Contracted competence is a control; it is not an exclusion. The same reasoning applies to the cleaning contractor, the waste contractor and the transport provider.