2-17. Typical Non-conformities in ISO 14001 Internal Audits and Tips for Correction

Common non-conformities found in ISO 14001 internal audits often relate to inadequate legal compliance, outdated environmental aspect evaluations, and poor record-keeping. Addressing these issues is crucial for passing external audits and genuinely improving environmental performance.

1. Insufficient Legal Compliance Evaluation

One of the most frequent non-conformities is a failure to keep the list of environmental laws updated or to maintain sufficient evaluation records. For example, not keeping up with revisions to the Air Pollution Control Act or Waste Management Act increases the risk of legal violations. To correct this, a system for regularly collecting information on legal revisions and consistently recording compliance evaluations at least once a year is necessary. Utilizing external databases or specialized organizations can make this process more efficient.

2. Formalization of Environmental Aspect Identification and Evaluation

Another common internal audit finding is the use of outdated environmental aspects and significance evaluations from previous years. When new processes or equipment changes are not reflected in the environmental impact assessment, it constitutes a non-conformity. The corrective action is to establish a rule that requires a review of environmental aspects whenever there are changes in equipment or new business operations and to document this review.

3. Inadequate Goal Management and Improvement Activities

Insufficient progress management or evaluation of environmental goals is also a typical non-conformity. An example is having a goal to "reduce CO2 emissions" but lacking data on the actual reduction or a verification process. The key to correcting this is to quantify key performance indicators (KPIs), check progress monthly or quarterly, and clearly define corrective actions for when goals are not met.

4. Insufficient Training Records

Even if environmental training is conducted for employees, the lack of records constitutes a non-conformity. This is particularly an issue for on-site training, such as chemical handling or waste sorting, where evidence can be difficult to maintain. The corrective action is to save attendance lists, training materials, and test results, and organize them so they can be easily presented during an audit.

5. Deficiencies in Document and Record Management

Document management deficiencies, such as the failure to distribute the latest versions of procedures to the workplace or leaving old versions in use, are also common. A helpful tip is to use a document management system to centrally control the latest versions and clearly document revision history. Always confirm that the latest version is being used during on-site inspections.

6. Unpreparedness for Emergencies

It is also common for internal audits to find that emergency response drills have not been conducted or that the scenarios are outdated. The corrective action is to create an annual drill plan and conduct exercises that anticipate various scenarios, such as fires, chemical spills, and natural disasters.

In an ISO 14001 internal audit, it is crucial to focus on three key points: documentation, implementation, and improvement. By understanding and continuously addressing these typical non-conformities, you can not only pass external audits but also truly improve environmental performance.