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How to show evaluation of compliance?

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Blackstone
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How to show evaluation of compliance?

Post by Blackstone »

Morning all,

My company recently had a 9001/18001/14001 audit (including changing to 2015 version of 14001 and 9001).

The auditor raised a NC against evaluation of compliance.

We have a compliance register with H&S / Environmental / Other tabs.
In each the Register states: The regulation (plus links to relevant info on the web), brief outline of how the regulation affects the company, what the company does to comply and changes during the compliance evaluation.

The auditor stated that there was no evidence of the evaluation. What did we check? How did we do it? What did we find?

How do you show the evidence of the evaluation in your company?
Would it be a big list of checks for each regulation?

I need to cover this off but want to do it in the most efficient way to make it repeatable every 6 months without taking up masses of time.

I look forward to hearing your solutions :)

Glen
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Re: How to show evaluation of compliance?

Post by quality_somerset »

Hi Glen

I had something similar happen to me when i introduced 18001. I turned the legislation register into a compliance audit sheet, if you PM me your email i will beam you over a copy so you can have a look at what i did. It passed the 18001 audit so it might help a bit.

Regards

QS
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Re: How to show evaluation of compliance?

Post by Dodds »

I do this via the internal audits, I did used to carry out a separate evaluation but it wasn't worth it.

Basically listed the legislation that applied and covered it during the audit. Way easier.
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Re: How to show evaluation of compliance?

Post by QHSS »

You need to be able to demonstrate objective periodic evidence of evaluation of legal compliance against all legislation on your legal register, ie show what you have looked at to evaluate that you are compliant , when you looked at that information evidence, who looked at it, then decide by evaluating are you compliant with the legislation applicable to your organisation or not???. its not just a big document that you compile once and stick it on a shelf or achive and blow the dust off when auditor turns up. you could be compliant to the legislation one moment, but things change and you may not be compliant now, so periodic evaluation needs to happen by competent persons who know enough about legislation to make the decision that you are compliant or not. If the HSE turns up or you get a civil claim in to your company youll sharp find out if your compliant or not, hence the need for periodic evaluation of compliance, Other standards have it under needs of interested parties internal & external. Its not about just changing the date on a document Im afraid.
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Blackstone
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Re: How to show evaluation of compliance?

Post by Blackstone »

quality_somerset wrote: Tue Jun 20, 2017 12:12 pm Hi Glen

I had something similar happen to me when i introduced 18001. I turned the legislation register into a compliance audit sheet, if you PM me your email i will beam you over a copy so you can have a look at what i did. It passed the 18001 audit so it might help a bit.

Regards

QS
QS - PM sent ./thumbsup.. Thanks
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Blackstone
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Re: How to show evaluation of compliance?

Post by Blackstone »

QHSS wrote: Wed Jun 21, 2017 8:53 am You need to be able to demonstrate objective periodic evidence of evaluation of legal compliance against all legislation on your legal register, ie show what you have looked at to evaluate that you are compliant , when you looked at that information evidence, who looked at it, then decide by evaluating are you compliant with the legislation applicable to your organisation or not???. its not just a big document that you compile once and stick it on a shelf or achive and blow the dust off when auditor turns up. you could be compliant to the legislation one moment, but things change and you may not be compliant now, so periodic evaluation needs to happen by competent persons who know enough about legislation to make the decision that you are compliant or not. If the HSE turns up or you get a civil claim in to your company youll sharp find out if your compliant or not, hence the need for periodic evaluation of compliance, Other standards have it under needs of interested parties internal & external. Its not about just changing the date on a document Im afraid.
I agree with you. I do the compliance checks twice yearly and record that I have checked, just haven't recorded the what when where bit to demonstrate I did it.
It's certainly not a paper exercise and just changing a date on the document. I take it seriously that if i'm covering the regulations, my employees will be safer and healthier.

I was just curious how others recorded there legislation checks ./thumbsup..
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Re: How to show evaluation of compliance?

Post by Dodds »

Hence doing it as part of the internal audit process, you have shown where you checked, simple. Its saved us a lot of time doing it this way.
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Re: How to show evaluation of compliance?

Post by Elf&Safety »

How do you currently review your legal register? How do you know the laws still apply? Add a column that shows examples of how compliance is met.

PUWER; pre-use checks on machinery, system of maintenance etc... When you review your legal register include comments of how you achieve compliance within each section. I would agree that combined with internal audits you should be able to meet this clause. My internal audits are on first aid provisions, LEV's, legal register, system audit (mainly regarding documents but looking at process flows), COSHH etc...

But some of those internal audits help show compliance to the relevant statutory provision. Also, discuss future regulation changes at a committee or management level and minute it to show that as a business you have considered, evaluated and implemented changes to comply.
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Re: How to show evaluation of compliance?

Post by QHSS »

You need to be able to demonstrate objective periodic evidence of evaluation of legal compliance against all legislation on your legal register, ie show what you have looked at to evaluate that you are compliant , when you looked at that information evidence, who looked at it, then decide by evaluating are you compliant with the legislation applicable to your organisation or not???. its not just a big document that you compile once and stick it on a shelf or achive and blow the dust off when auditor turns up. you could be compliant to the legislation one moment, but things change and you may not be compliant now, so periodic evaluation needs to happen by competent persons who know enough about legislation to make the decision that you are compliant or not. If the HSE turns up or you get a civil claim in to your company youll sharp find out if your compliant or not, hence the need for periodic evaluation of compliance, Other standards have it under needs of interested parties internal & external. Its not about just changing the date on a document Im afraid.
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