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Integrated Supply Chain Information

8 Integrated information

• 8.1 Introduction
• 8.2 Combining the data collection
  • 8.2.1 Overlapping data requirements
  • 8.2.2 Overall data synergy effect considerations
• 8.3 Combining the verification processes
  • 8.3.1 Verification or certification
  • 8.3.2 The verification process
  • 8.3.3 Verifier qualification and competence
  • 8.3.4 Integrated verification of information systems.

8.1 Introduction

The aim of this chapter is to present and discuss possible synergy between the schemes presented in the previous chapters.

In all presented schemes there is a flow of elements/tasks to be carried out and concluded to meet part of the requirements in the schemes and regulations. These tasks are illustrated in the flow chart in figure 4 (each scheme to be read vertically). This also illustrates the areas of possible synergy (highlighted by arrows in figure 4).

The dotted boxes in the flow chart illustrate different background documents, which are or could be used in the different schemes, as they are very valuable information input in preparation of the tasks.

In the following, the synergies are discussed in relation to:

• the data collection process and the mapping of environmental aspects and impacts in the five schemes
• the verification process in the five schemes

8.2 Combining the data collection

All the data supply chain schemes are based on data of various details and presentation form. The data requirements of the information systems can roughly be divided into two layers: Background information and information needed to document compliance. Key aspects regarding the data requirements of the different systems are presented in the previous sections and are summarized in table 11

Click here to see the Figure 4.

Click here to see the Table 11

8.2.1 Overlapping data requirements

The data requirements needed to fulfil the criteria of each scheme are similar in several sections but rarely identical.

The environmental information required by the schemes in general is outlined in Table 12.

One of the main barriers is the inconsistency in the designation of the environmental impact categories. The environmental impact for one category is assigned different names and definition depending of the information system. One way of overcoming some of the obstacles regarding this problem is to merge the initial investigations. Coordinated initial data collection guidelines – one for product-specific verification tools (EPD and eco-labels) and one for site-specific tools (EMAS and IPPC) are recommended. It is recommended to carry out the data collection for SDS individually as the objective of this communication tool differs from the others. A pathway for input to the implementation of the new chemical regulation of chemicals should be established, especially for articles (goods). A common LCA-investigation ^[20] and common definition of impact categories for EPD and the EU-Eco-label would give significant synergy effects. When the initial LCA investigations are carried out, specific individual criteria/impact categories can be established as the target groups for the two systems are not the same.

When establishing criteria for fulfilling the requirements of the EU Eco-label it is recommended to use the same cut-off values as stated in the SDS. By using the same cut-off criteria, the information may be collected directly from a SDS whether a product can comply with the EU Eco-label criteria or not.

A similar co-ordination could be achieved by coordinating the emission data applied in IPPC and EMAS.

Overlapping data requirements occur for a number of environmental impact categories depending of the information system as outlined in Table 12.

Some of the information tools contribute as suppliers for others. For example, SDS may, if the data collection and presentation is coordinated, be used directly for an Eco-label or EMAS certification.

A broadly accepted data foundation and collection strategy would ease the data collection process significantly. This would require a co-ordinated management of all schemes to be established.

Click here to see the Table 12

Table 13 Identified synergies regarding data collection.

8.2.2 Overall data synergy effect considerations

Table 13 identifies examples of synergy in data collection coordination between the schemes. The identification is sub-divided into background documentation (in-put) and presentation data requirements (out-put).

In general, there is overlapping data requirements within the different supply chain information systems. A co-ordination of the data collection strategy and an introduction of common terms for the description of the impact categories could give a significant synergy effect. A centralized set-up of uniform data criteria is recommended as the workload of the data collection process could be significantly reduced.

Additionally, it is recommended that common criteria for the assessment of conversion coefficients estimating product-specific data from site-specific emissions should be implemented.

An optimal planning of the data collection process will also ease the verification process for the 5 systems.

8.3 Combining the verification processes

All schemes include a verification process performed by an external verifier, but each scheme has its own verification process and its own data requirements for the verification process.

Seen from a company point of view they already have too many "verifiers" coming into the company. There are health and safety inspectors; environmental authorities; quality auditors, if they have an ISO 9000; EMS auditors; eco-labelling inspectors; and in the future there might even be Environmental Product Declaration verifiers.

In the previous chapter we showed that there are overlapping data requirements, but the verifiers are asking the companies to present them in different ways according to the various verification requirements.

Although environmental verification is based on the same core group of data and information it can be very overwhelming and a barrier to participate in one or more of these voluntary schemes for many companies. It would be an advantage to many companies if the core data and information could be verified at one stage and not several times depending on the scope of the different verifications.

Therefore the question is whether it would be possible and feasible to combine the verification process and assessment visit of these schemes as far as possible to avoid unnecessary duplication, cost and time of the company? Would it be possible to let one environmental verifier carry out the total verifying process of all the relevant schemes at the same time?

8.3.1 Verification or certification

EMAS has a verification process, in ISO 9000 and 14001 it is called a certification process, in the Eco-labelling it is called a control, and in the national EPD schemes globally, both verification and certification is used. At the moment, verification is used as the term in the committee draft of the ISO 14025 on environmental product declarations.

Here the term verification is used in the meaning: ”confirmation, through the provision of objective evidence, that specified requirements have been fulfilled” ^[21].

There is an on-going discussion on who should be doing the verification. It is the question about first, second and third party verification:

• First party = Demonstrate conformity making a self-determination and self-declaration
• Second party = Seek confirmation of its self-declaration by the customer
• Third party = Seek verification by an external person or organization independent of the producer and receiver of the information. Independence may be documented in the form of an accreditation by a competent body (authority or other credible and independent organisation)

SDS and IPPC schemes are verified by the authorities. They are regulatory mandated controlling procedures, which cannot (should not) be combined with voluntary schemes including third party verification, because the legal status of an authority and a third party verifier is different.

This project only discusses third party verification and does not differentiate between an individual (accredited) person being the verifier or if a body (organisation) carries out the verification.

The following is based on official documents on the EMAS verification process; on the practice for eco-labelling controls in Denmark and public available document on the EPD development in ISO, Sweden and other countries. There has been no formal contact with any verification bodies, accreditations bodies, but a few interviews have been carried out with experts on verification to clarify specific issues.

8.3.2 The verification process

EMAS verification

To prepare for an EMAS verification process, the companies work directly from the EMAS regulation (or the ISO 14001 standard) as their tool. In some countries there may be a sector specific manual explaining the requirement, particularly related to the significant environmental aspects of the sector. These are, however, only to be regarded as voluntary guidance documents.

In consultation with the company, the verifier must design a programme to ensure that all elements required for registration with EMAS are verified in a period not exceeding 36 month. This requirement of designing a programme is similar to the requirements of ISO 14001 and other ISO management standards, and in most cases the verifiers visit the company ones a year.

An EU guidance document on verification, validation and audit frequency recommends regular interaction between the verifier and the company, because it helps creating credibility and confidence in the users of EMAS as well as the scheme itself. In order to ensure ongoing surveillance of the organisations, EMS and the environmental performance, good practice would be to structure the verification so that one third of the activities of the organisation are verified each year and within a period of maximum 36 month all activities have been verified. This will also help to give confidence to the verifier on the accuracy, credibility and reliability of information in the environmental statement.

Eco-label verification

A general process of product information verification for the use of the Eco-label is not specified in the Eco-label Regulation or any other official documents, such as for instance for the Nordic Swan label. The criteria document describes the requirements the product must meet and how it must be documented, but it is not specified, how the verification of the documentation should be effected.

It is up to the national competent body to set up rules for the process. This might indicate the possibility of different rules in different countries under the same scheme and thus different stringency of the verification. For compliance control in Denmark, the competent body has developed internal procedures for the verification process.

The producer must put forward an application in which the company documents the fulfilment of the criteria for the product group in question. The process therefore seems similar to the process in an application under the IPPC directive. At the end of an application period – when the documentation is in place – the Eco-label secretariat or a person appointed by the administration will make a compliance monitoring visit.

An eco-label verification must be renewed when the criteria document has been revised and updated. The interval of updating is for most product groups three years – for some up to six years.

EPD verification

In the Swedish EPD® system, an independent verification of the information in an EPD is guided by ISO 14040: Life Cycle Assessments - General Principles and Framework stating that the results of any LCA study must be critically reviewed if the information is to be used for comparative purposes.

An independent and accredited certification body conducts the verification. There are currently several certification bodies accredited for ISO 14001 and EMAS, which also hold an accreditation for EPD to enable cost-effective integrated certification services to their clients. The independent verifier must validate the quality and accuracy of the data and the supporting information in the EPD based on all information given.

The presentation of the LCA study must be comprehensive with regard to the way the study has been carried out and the results of the study. The relevant PCR used as a basis for the EPD must be referred as well as the valid requirements for environmental product declarations.

In the draft ISO/DIS 14025 standard detailed requirement for the verification process is described. The standard requires that when developing an environmental declaration programme, the rules for verification must be set up in accordance with ISO 14025, ISO 14040 and ISO 14020 and the programme operator must establish the appropriate verification procedure, also including that the data must be independently verified either internally or externally, but not necessarily by third party verification.

ISO/DIS 14025 requires a review of the PCR document conducted by a third party panel. The PCR review must demonstrate that:

• the PCR has been developed in accordance with ISO 14040,
• the PCR fulfils the general programme instructions,
• the LCA-based data together with the additional environmental information prescribed by the PCR describe the significant environmental aspects of the product.

ISO/DIS also requires an independent verification of the EPD data and of additional environmental information, which as a minimum must confirm:

• conformity with the PCR
• conformity with ISO 14040 series of standards
• plausibility, quality, accuracy and completeness of the LCA-based data
• quality and accuracy of data

The verification procedure must be transparent. The independent verifier must generate a report documenting the verification process. This report must be available to any person upon request. The verification procedure must confirm whether the information given in the EPD accurately reflects the information in the documents on which the declaration is based. The verification procedure must also confirm whether this information is valid and scientifically sound.

The PCR review and the independent verification of an EPD are two separate processes. The independent verification of the EPD may be carried out by the

PCR review panel or may be carried out by an independent verifier who may or may not have been a member of the PCR review panel.

An EPD verification is usually valid for three years.

The steps in the verification process in the EMAS scheme, the Eco-label scheme (based on the applied procedures at the Eco-labelling Denmark) and the EPD scheme (Sweden) are outlined in Table 14.

The SDS and the IPPC authority controls are not included in the table, because they are regulatory mandated controlling procedures, which cannot (should not) be combined with voluntary schemes including third party verification (although the same stringency of procedures and evaluation should be applied to assure the same level of verification quality).Table 14 Steps in the verification process - Comparison between the three schemes

8.3.3 Verifier qualification and competence

General

In all three schemes there has been – and are on-going – discussions of the qualifications of the verifier to make sure that the schemes and the verification processes enjoy the expected credibility.

It is also an issue whether the verification of schemes should be open to anybody able to document sufficient qualifications or only to appointed organisations.

Another issue is whether only third party verification should be accepted. For both EMAS and Eco-labelling this issue has been solved by the regulation and only third party verification is accepted. In EMAS, an accreditation of the certification body is required. In the Eco-labelling scheme there is no accreditation process. In some countries the scheme is run by the authorities in others the authorities have outsourced the administration including specific requirement on how to run the administration. This means that most administrations have a quality management system of the schemes setting up some quality requirements. In the various national EPD schemes there are still different requirements – some require accreditation of the verifier - others have other means to ensure credibility of the verifier.

EMAS

In the EMAS regulation it is stated that it is necessary to ensure and steadily improve the competence of the environmental verifiers by providing for an independent and neutral accreditation system, retraining and an appropriate supervision of their activities in order to ensure the overall credibility of EMAS. Close co-operation between the national accreditation bodies is underlined as a necessity as well.

The following competence constitutes the minimum requirements with which an environmental verifier, individual or organisation, must comply:

• knowledge and understanding of the general functioning of environmental management systems, relevant standards and guidance
• knowledge and understanding of the legislative, regulatory and administrative requirements
• knowledge and understanding of environmental issues, including the environ-mental dimension of sustainable development;
• knowledge and understanding of the technical aspects, relevant to environmen-tal issues, of the activity subject to verification;
• understanding of the general functioning of the activity subject to verification in order to assess the appropriateness of the management system;
• knowledge and understanding of environmental auditing requirements and methodology;
• knowledge of information audit (Environmental Statement).

Appropriate evidence of the verifier's knowledge and of his/her/its relevant experience and technical capacities should be assessed by the accreditation body.

Eco-labelling

There are no general rules for the qualifications of the verifier in the Eco-labelling scheme, but the individual countries have qualification requirements. The following requirements are from Eco-labelling Denmark.

For the first period of his/her appointment, a new person is placed as a trainee together with a more experienced controller. In this period the trainee is trained in regulatory matters, the sector specific technology and environmental issues in questions and audit and interview techniques. After this period the trainee will get his/her own application to approve, but still with supervision from the experienced controller.

After three control visits together with the more experienced controller, the trainee is left on his/her own as a qualified controller.

The main training issues as mentioned above are described in the quality management system of the (Danish) verification body.

EPD

In the proposal for an ISO/DIS 14025 on Environmental Product Declarations the qualifications of a verifier are specified:

The programme operator must establish minimum requirements for competence of verifiers, including:

• knowledge of relevant sector, product and product-related environmental aspects
• process and product knowledge of the product category
• expertise in LCA and methodology for LCA work
• knowledge of relevant standards in the fields of environmental labelling and declarations and LCA
• knowledge of the regulatory framework within which requirements for environmental declarations have been prepared
• knowledge of the EPD programme.

In each of the existing national schemes, the qualifications of the verifier are specified in even more detail, especially in terms of how much practical experience is required.

In South Korea, the requirement is either 2 years of LCA related working experience, 5 years of working experience related to industrial process control or 7 years of working experience related to Environmental Management Systems. In Japan, the verifier must be an EMS auditor and have passed a system auditor and an environmental data verifier examination. The verifier must carry out an EPD verification twice a year in three years.

In Sweden and Denmark, the work experience is important as well, but combined with an exact experience in elaborating a LCA-study. Only in Japan and South Korea the qualification of the verifier is linked to experiences in Environmental Management Systems, although in Sweden the actual verifiers are also EMS verifiers.

The different qualifications and competences requirement by the verifier is outlined in Table 15. The documentation is based on the EMAS regulation, the management procedures of the Eco-label scheme at the Eco-labelling Denmark and the EPD scheme in Sweden.

Qualification requirements of the authority controllers in relation to SDS and the IPPC have not been analysed – although it is anticipated that sufficient qualifications may be documented also by the authorities.

As it can be seen, all three schemes are demanding experience in the relevant industrial sector, working experience in the environmental area and knowledge of the regulatory framework. As it appears, there seem to be requirements for similar qualification on the overall level, but at a detailed level there are no LCA qualification requirements in EMAS and no auditor qualification requirements in the EPD. A verifier from one or the other scheme, who would like to be a verifier in all three schemes, needs more competence and qualification or should he join a team, where the team as a whole has all the needed qualifications. This is discussed further below.

Table 15 Comparison of qualifications and competence requirements in the three schemes

8.3.4 Integrated verification of information systems.

Over the years, several companies – especially the SMEs – have indicated that it would be valuable for them to have an integrated verification system used for different schemes: EMAS, Eco-label and EPD. In the following is discussed whether such a system could be established and what would be required from the verification bodies.

The EMAS verification system is chosen as the basis element for a possible integrated verification system, because EMAS already has the most developed and experienced verification system and because it already provides for product coverage. As an example, an EMAS registered company must identify its significant environmental aspects and the EMAS Regulation advises the company to include product considerations:

“Considerations in establishing the criteria for assessing the significance of an organisation's environmental aspects may include “...(f) design, development, manufacturing, distribution, servicing, use, re-use, recycling and disposal of the organisation's products;” (EMAS, Annex VI, 6.4)

Certification of Environmental Management Systems

Certification of the Environmental Management System is standardised worldwide through a set of Guidelines.

The ISO/IEC Guide 66:1999 ^[25] is a short International Guide which sets out the overall criteria and requirements for bodies operating with assessment and certification / registration of the Environmental Management System. For bodies accredited and working globally, it has been necessary to provide more guidance to ensure that certification and verification are carried out in a harmonised manner. The EA Guidelines (EA 7/02) for accreditation of certification bodies for the environmental management system provide such guidance.

The main issue of the ISO guide is to ensure that the certification/registration body is able to conduct assessments across the entire range of its activities using resources under its own control which meet the ISO requirements on auditing ^[26] - ISO 19011.

Figure 5 Guidance documents assisting the verification/certification body in EMS certification and EMAS verification

Auditor competence

It is a condition of accreditation that accredited certificates must not be issued until adequate resources can be deployed to conduct an audit. The certification / registration body's procedures must ensure that staff employed to assess the organisation are competent in the field in which they are operation.

The ISO guide EA 7/02 puts a lot of emphasis on the competence of the staff directing and managing the certification process (Clause G4.2.7-15) because they represent the pathway to ensure the credibility of the certification process. The essential elements are to select, provide and manage individuals whose collective competence is appropriate to the activities to be verified and the related environmental aspects.

The certification body must have criteria for training and selection of audit teams that ensure appropriate competent levels of:

• Understanding of the EMS standards
• Understanding of environmental issues
• Technical knowledge of the activity to be audited
• Knowledge of regulatory requirements relevant to the EMS
• Management system audit competencies
• EMS knowledge

Each member of the audit team or the audit team as such should at least be familiar with:

• the EMS standard
• the concept of management systems in general
• issues related to various environmental media (such as air, water etc.)
• auditing principles and methods
• knowledge of legislative, regulatory and legal requirement in the environmental field
• current technical knowledge of the specific sector
• techniques to reduce harmful environmental impacts and the application of these techniques in practice

ISO 19011 has also specific requirements with respect to the knowledge and the skills of environmental management system auditors (ISO 19011, clause 7.3.4.). These are similar to those referred to above but are more specifically related to environmental science and technology.

ISO 19011 is also more specific in relation to the technical and environmental aspects of operations. Knowledge and skill in this area should enable the auditor to comprehend the interaction of activities, products, services and operations with the environment

Competences in relation to eco-labelling and EPD verification.

If an EMAS verifier was to carry out an eco-label assessment and EPD verification as well, the requirements should be extended to comprise:

• genuine knowledge of the eco-label and EPD-schemes in question
• knowledge of the criteria document and EPD-PCR in question

More detailed the main differences between the EMAS verification, the eco-labelling and the EPD verification is the expanded focus on:

• products – requiring current technical knowledge of the product, knowledge of the critical environmental characteristics of the product and product specific terminology body.
• life-cycle approach and assessment –requiring knowledge of LCA methodology and techniques such as the ISO 14040 series. A requirement mainly in relation to the EPD verification
• performance evaluation and data auditing – requiring a broader and more comprehensive knowledge on test, monitoring and measurement methodologies. It should also be recognised that data auditing is a task that differs from auditing control requirements.

These competences could be further elaborated and presented as specific knowledge requirements in the audit team, if an integrated verification was to be performed.

Stages in the audit process

The EA Guidelines (EA 7/02) for accreditation of certification bodies for environmental management systems set up requirement for the application for the certification process (hereafter the audit) and the stages to be included. These are divided into stage 1 and stage 2. Stage 1 is a review of documentation and the planning process of the site audit. Stage 2 is the actual assessment of how the system works on site and finding objective evidences. This is further explained below including an explanation of the similar element in an eco-label assessment and EPD verification.

Stage 1

Document review

Companies requiring EMAS-verification must document their Management System. This means that the verifier must review the available documented evidence to assess that the documentation requirements in EMAS are met. The EMAS statement is an essential document and requires special attention from the verifier.

An application for Eco-labelling must include all required certifications and necessary documents and a procedure concerning changes of the product. The application is to be completed with the enclosures (e.g. test reports, measurement data, etc.) that are required in accordance with the criteria document for the particular product group. The verifier must conduct a document review to ensure conformities in the documentation compared to the criteria document.

The application for a verification of an EPD includes the actual EPD and an EPD report, and the verifier will go through the documentation to see if the LCA is conducted as set out in the PCR and the relevant ISO standards (ISO 14020, 14025, 14040), assess data and how they are calculated.

Initial visit

The initial visit is performed to obtain a clear picture of the complexity of the organisation's operation and to provide a focus for planning the audit stage 2 and to achieve an understanding of the EMS in the context of the organisation's environmental aspects and associated impacts, policy and objectives and in particular the organisation's preparedness for the audit stage 2. It must also ensure that the organisation fully understands the verification process. The information gained must serve as a basis for audit planning.

No initial visit is conducted in the Eco-label and EPD verification process.

Stage 2

Audit Programme

A detailed audit programme is issued to the organisation prior to the EMAS-audit. The objectives of the audit (stage 2) are to confirm that:

• the organisation adheres to its own policy, objectives and procedures
• the EMS conforms with all the requirements of the EMS standard and is achieving the organisation's policy and objectives
• the information in the environmental statement is correct

To do this, the verifier must address the implementation of the EMS. The extent of the audit stage 2 should be influenced by the degree to which the auditor can rely on the organisations internal audit

There is no detailed audit programme in the Eco-label and EPD verification process, and there is no internal audit that the verifier can rely on.

Verification-Audit

The objective of the EMAS verification-audit is to ensure that the company's documented Management System and Environmental Statement complies with EMAS and the documented system and procedures/instructions are implemented sound and properly through site visits and interviews with selected personnel. If however non-conformities are identified, non-conformity notes are given.

An Eco-label verifier also conducts a site visit at the organisation to find non-conformities in the performance compared to the criteria document.

For the time being, only a few the EPD schemes require an audit or site visit in the organisation, and it is not included as a requirement in ISO 14025.

Technical review and issue of certificate

When the auditor has ensured that all activities stated in the EMAS assessment process have been completed and all non-conformities are closed, he/she hands over the audit file to the authorised person for technical review. The authorised person must review the records in order to verify that the documentation is satisfactory. If the documentation is found satisfactory, a certificate/verification diploma may be issued.

The EU Eco-label has no such requirement as a technical review, but it is a practice with many of the Eco-labelling administrators. For instance it is a requirement in the procedures of the Nordic Swan label. The verifier conducts a technical review and if an application is approved, the label is awarded.

There is no suggestion of a technical review in the ISO/DIS 14025 and it has not been found in any of the existing EPD schemes.

Registration

When above procedure has been completed, the validated statement is sent to the Competent Body to be published and registered. The company is now listed in the register of EMAS organisations and has the right to use the EMAS logo.

Similarly, companies with the Eco-label and an EPD will be registered by the Eco-label competent bodies and the EPD programme operator.

Definition of the scope, organisation, site and products

Another important issue to take into account when discussing integrated verification is the different scopes of the information systems.

In an Environmental Management System, the scope of the system is either defined by a specific location (a site) or the boundaries of the organisation. In the Eco-label and the EPD, the function of the product and the product chain defines the scope. and also when a company decides to have a product label or an EPD on one selected product (product category), but not all its products. One could say that EMAS includes part of the product chain and the product-oriented schemes include part of the production site.

In several places, EMAS refers to a product-oriented approach from the (initial) environmental review to the final environmental statement. However, the EU has not prepared any guidance with respect to the extent and the integration of the product in EMAS. Few interviews give the impression that EMAS seems to be dealt with in various ways by the verifiers and to various degrees in companies EMAS systems.

The element of product verification in the EMS verification has been discussed by the Forum for Accredited Bodies in Europe (FAB), but no conclusion and/or guideline has been developed yet. Also the EA 7/02 and ISO 19011 have elements of product related issues, but these elements have to be exploited further to ensure that the different scopes do not contradict each other. It should still be possible in an integrated verification to have a complete management system assessment, but only selected products assessed.

Surveillance audits

The surveillance audit process is the core of EMS verification maintenance and must be planned and executed to ensure a continuing evidence of an acceptable maintenance of the management system. The surveillance audit is based on 12-month intervals and must cover all parts of the management system within the 3-year life of the verification. All verification bodies must have clear procedures laying down the circumstances and conditions in accordance with which the verification will be maintained.

The verification of an Eco-label and an EPD does not include any surveillance audit. But again such a procedure is known from the Nordic Swan label, where the Eco-label verifier conducts an assessment within the verification period. This means that the working process in the Eco-label scheme in companies (and expectedly in the EPD) is reconsidered every three years when the application must be renewed, while an EMS working process is continuous and on-going.

By including a surveillance audit in an integrated verification process, the Eco-label and EPD schemes might gain credibility and make the benefits of integrated information processes more obvious, because the same data are gathered for more purposes at the same time. It might benefit many companies to have a more continual and integrated working process and not only an integrated verification.

The ISO guide EA 7/02 sets up specific guidelines for the surveillance audit.

An EMAS verification is normally valid for a period of three years. A re-assessment audit must be carried out before the verification can be renewed. In principle, the re-assessment audit is similar to the initial audit, but because of the knowledge collected during the surveillance audits, it will normally take the form of an extended surveillance audit ensuring that all elements are audited.

The Eco-label verification and the EPD verification are valid as long as the criteria document is valid – for three years or more - and the organisation must send a new application after the three years according to the new criteria document and the new PCR and the application process starts again.

Conclusion

A common and integrated verification process of the voluntary information schemes could be established and create benefits especially for the small and medium sized companies and it could create more credibility to the verification of the individual schemes especially the Eco-label schemes which today have no common European verification framework.

It is possible to develop a better process, which would benefit not only the companies but also the verifiers, competent bodies and other stakeholders and it would gain credibility in all three schemes seen as an initiative to make the verification process less bureaucratic. But today it would require further qualifications of most verifiers, who should also have thorough knowledge of all schemes in question.

There are no formal restrictions in EMAS on an integrated verification process. On the contrary, EMAS already provides for inclusion of the product-oriented issues.

Both the EMAS (via the EMS accreditation schemes) and some of the EPD schemes have very precise descriptions of the verification process. The Eco-label does not have the same general description, which makes the comparison inexact because some elements existing in the EMAS and EPD schemes might also exist in one or more of the national description of the assessment process in the Eco-label.

With regard to the Eco-label, a missing overall description of the verification process means that many different individual procedures have been developed in each country and this may lead to non-consistent verification in different countries.

The main wish from companies and organisations is to get a less bureaucratic and time-consuming verification process. Some of the main benefits of an integrated verification process are that the companies will save time preparing the audits, they would only have to prepare one documentation file and their presence at the verification audits would not be required.

Many of the elements in a verification process are similar and have the same heading when the verification process in general is described. However, a closer look at the verification task reveals that the requirements for the elements are rather different.

The main benefit is that the verifier (audit team) will have a better understanding of the company having gone through more product-oriented material in relation to the Eco-label and/or the EPD as part of the document review. This knowledge should lead to a more efficient planning of the audit programme and the verification audit.

Examples in both the Swedish and the Japanese EPD schemes show that they use the same verifier – person or body – as in EMAS. In addition, some countries use an EMAS verifier or EMS auditor (ISO 14001) for the Eco-label assessment visits. These experiences could be exploited further.

However, the benefits might still depend on how the audit team is set up and on the personal skills of each auditor, who should be able to understand both the idea of a management system audit and a performance audit and be able to create trust and confidence in the relationship with the client.

As stated in ISO19011, p. 21-23, “it is a matter of trust and confidence to be an auditor or controller and be able to pass the right questions to get a trustworthy answer. Trust and confidence in relation to a customer is created on the basis of the auditor/controllers personal skill and attitude.”

It has not been part of the framework of this study to look into the pricing of an integrated verification, but it seems possible that the initial costs of starting one verification rather than two or three should lower the costs.

Click here to see the Figure 6

Footnotes

[20]A common LCA- foundation shall as minimum follow the ISO 14040, have a common Functional Unit, System Boundaries and Data Requirements.

[21]ISO9000:2000

[22]based on the document “EMAS guidance on verification, validation, audit frequency”

[23]based on interview with Eco-labelling Denmark

[24]based on ISO 14025 and the Swedish EPD scheme

[25]The guide in under revision and will be published as ISO 17021 in 2005

[26]EA 7/02 – Issued by the European co-operation for Accreditation in Dec. 2001 refers to the Environmental Management Systems Auditing standards ISO 14010, 14011 and 14012. Today, these have been taken over by ISO 19011: Guidelines for quality and/or environmental management systems auditing, 2003

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