BuildRight: A New Asphalt Plant Outside the EMS

The new plants are a significant change that the EMS has not absorbed.

• 6.1.4: The organization must plan actions to address significant aspects, compliance obligations, and risks and opportunities. New asphalt and concrete plants introduce air emissions, dust, water use, wastewater, chemical storage, and permit conditions. These should have been assessed before mobilisation, with actions integrated into the EMS.
• 8.1: Operational control must cover the new processes, including criteria, controls, and controls for outsourced or contracted activities. The absence of the plants from the scope and aspects register means there is no operational control framework.
• 10.2: The repeat spill-kit finding shows the corrective action was ineffective. A toolbox talk is not a corrective action for an empty spill kit; it addresses awareness but not the cause.

Before mobilisation, BuildRight should have updated the scope, identified aspects and compliance obligations, obtained or verified the permit, set objectives, planned operational controls and emergency arrangements, ensured competence, and defined monitoring. Management review should have decided on resources and EMS changes. Proceeding without this is a system failure, not just a documentation delay.

A toolbox talk can raise awareness, but it does not fix the reason the kit was empty. The cause is likely a missing management process: no inspection schedule, no assigned owner, no replenishment route, no checklist, or no verification after use. If the talk was the only action, the same conditions remain, which is why the finding recurred. That recurrence is evidence that 10.2 was not effectively implemented.

A proper root-cause analysis might ask:

• Who is responsible for checking the kit, and is that responsibility documented?
• How often is it checked, and where is the record?
• How are used items replaced, and who authorizes the purchase?
• Was the kit used in an incident, and was there a process for restocking?
• Do site staff know how to report a missing item?

Likely causes include no inspection regime, unclear ownership, or a purchasing delay. Corrective actions would then include a scheduled inspection, named responsibility, stock control, verification, and a check at internal audit. The effectiveness check should confirm that kits are complete at several sites over time, not just that a talk was delivered.

The auditor should judge by evidence that the EMS has changed before the activity starts, not by promises.

I would verify:

• the scope includes the new region and the plants, or a clear justification if not;
• the aspects and compliance obligations registers cover construction, asphalt production, and concrete batching, including normal, abnormal, and emergency conditions;
• the permit status and whether mobilization before permit issue creates a compliance risk;
• objectives and targets relevant to the new activities;
• operational controls and criteria for emissions, dust, water, chemicals, and waste;
• emergency preparedness for spills near the river;
• competence and awareness of new staff;
• monitoring and measurement for the new processes;
• internal audit coverage and management review decisions on resources and EMS changes;
• corrective action effectiveness for the repeat spill-kit finding.

If the plants are already operating without these elements, I would raise a nonconformity against 6.1.4 and 8.1, and consider 10.2 for the repeat finding. The key question is whether the EMS is controlling the new activities in practice, not whether a procedure has been drafted.