Commission Implementing Decision (EU) 2017/2286Show full title

Assessment of corresponding ELH requirements

1. Check of key characteristics of operations and assess conformity of the EMS with the organisation's policy and programme through an internal audit

Based on General Industry criterion (GIC) 6, ‘The management must perform an annual review of the HSE system and of Eco-Lighthouse procedures to assess whether they work as intended’. Note that this criterion is marked with the § which indicates legal basis.

The guidelines to GIC 6 also state that ‘The legal authority for the criterion is the Regulations relating to Systematic Health, Environmental and Safety Activities in Enterprises (Internal Control Regulations), section 5.8. The enterprise must monitor the HSE system and annually implement the system and internal audit to ensure that the HSE system works as intended. The Eco-Lighthouse procedures for external environments must be integrated with the HSE system and be made an inherent part of the internal audit. The management has main responsibility for the HSE system and for the integrated Eco-Lighthouse procedures, and must annually review them to ensure that they work as intended. How managements conduct the review in practice will vary between enterprises. The important point is to find practical solutions. (…)

NB: In addition to examining the criteria related to HSE, it is important that the consultant/enterprise also examines the enterprise's HSE system as a whole. The consultant/enterprise must examine whether the HSE system works well in practice and is well structured’.

The annual management review and the additional documentation and procedures required by ELH certification work therefore in tandem with the legal obligation to constitute an annual audit of the organisations' HSE activities according to the Norwegian Internal Control Regulations(1) (ICR). Through this integrated review process the enterprise must examine whether the HSE system works well in practice and is well-structured.

This results in an integration of the ELH's environmental procedures into the already existing HSE system and a strengthening of the management system as a whole both in regard to the working and the outer environment.

The audit/checks are based on specific sectoral check-lists, templates and examples provided by the ELH foundation and mirroring the level of environmental risk of the different sectors. The check shall also include a review of the Eco-Lighthouse procedures and the self-defined environmental goals, aims and achievements as defined in the annual Climate and Environmental report.

Depending on the size of the company, the system can be checked prior to the annual management review by an internal auditor or for small businesses during the meeting itself. In the annual management review, deviations and achievements, goals and aims are evaluated and new ones are set.

In complement to the Management Review, the annual Climate and Environmental report constitutes additional documentation of environmental goals and achievements. It assesses the items above, checks if progress has been made and aims have been reached and sets new aims for improvements in the forthcoming year. It is assessed by the management every year during the annual management review.

2. Correction of non-conformities

The aim of the HSE review is to pinpoint weaknesses and shortcomings and make a plan for rectification. Any shortcoming would lead to an action plan with the aim to eliminate the shortcoming (by a specific deadline).

Compliance with all criteria is needed before certification or recertification can be done, in particular with the general and specific criteria which are incorporated directly from Norwegian legislation. Non-compliance (also with legal provisions outside ELH) is dealt with by General Industry criterion 1950 which obliges enterprises to establish procedures for reporting and handling this non-compliance.

Any non-conformity with a criterion appearing during the certification or re-certification process would put on hold the ELH certification.

3. Report to the management on the conclusion and findings of the audit

The annual HSE report with the resultant action plan and the annual climate and environmental report are presented to the management at the occasion of the annual management review.

(1)

Excerpt from ICR guidelines ‘Periodical review of health, environmental and safety activities. In addition to the regular follow-ups (e.g. safety inspections, personnel meetings, etc.), the enterprise must, at least once a year, carry out a more comprehensive review of HSE activities and evaluate whether they are working in practice. The enterprise must have a written routine for the review. The results of the review must be readily accessible. The object is to pinpoint weaknesses and shortcomings and to rectify them. It is important to find the causes and ensure that they do not recur. After the review is completed, concrete objectives must be set for improvements, in addition to the overall objective’. Extracted from: www.arbeidstilsynet.no/binfil/download2.php?tid=77839 (pdf version of guidelines and regulation on Systematic health, environmental and safety (HES)). Full regulation available under http://www.arbeidstilsynet.no/fakta.html?tid=78950 and in English under: http://www.arbeidstilsynet.no/artikkel.html?tid=78622