IA202607 — Environmental Management¶
Audit Record
| Field | Value |
|---|---|
| Audit reference | IA202607 |
| Area audited | Environmental management — the requirements specific to ISO 14001 |
| Audit criteria | ISO 14001:2015 clauses 6.1.2, 6.1.4, 8.1, 8.2 and 9.1.2 · SOP 9.1, 9.3, 9.4, 9.5 · POL_HSQE_10 |
| Audit date | 08/05/2026 |
| Auditor | Sean Ashton, HSQE Consultant, Onyx Operations Ltd |
| Auditees | Aaron Mason (Director), Jason May (Site Supervisor) |
| Result | Conforms. 0 non-conformities, 1 observation |
| Previous audit of this area | IA202507, 2025 cycle |
| Form | FORM_INTAR001 Rev 1 ID 01/09/2025 |
1. Scope, criteria and independence¶
1.1 Scope¶
The requirements ISO 14001 places on AMWS that the other two standards do not: environmental aspects and their significance, the lifecycle perspective, operational control of the aspects that matter, and the evaluation of environmental compliance.
Clauses examined: 6.1.2 environmental aspects, 6.1.4 planning action, 8.1 operational planning and control, 8.2 emergency preparedness and response as it bears on environmental release, and 9.1.2 evaluation of compliance. Waste is examined in depth as the principal aspect.
1.2 Independence¶
The auditor is an external HSQE consultant engaged through Onyx Operations Ltd. He is not an employee of AMWS and holds no line responsibility for the work audited. SOP 6.2 requires that an auditor does not audit work for which they are also responsible; AMWS has no second competent auditor, and the consultant drafted much of the documented system. The mitigation applied is that no document is tested against its own wording. Each clause is tested against records, against what the people responsible describe doing, and against what can be produced on request. Findings are reviewed and countersigned by a Director, who holds the authority to accept or reject them.
2. Method and sample¶
| Method | What was covered |
|---|---|
| Document review | SOP 9.1 Aspects & Impacts Issue 3 (01/05/2026) · SOP 9.3 Environmental Protection, Land & Water Issue 3 · SOP 9.4 Management of Waste Issue 3 · SOP 9.5 Hazardous Waste Issue 3 · POL_HSQE_10 Environmental Policy Revision 3 |
| Registers examined | APP_06 Environmental Aspects at Issue 2 · APP_15 Lifecycle Analysis at Issue 2 · APP_10 Legal & Compliance Register at Issue 2 · APP_16 and APP_18 at Issue 2 |
| Records sampled | The Environment Agency Waste Carrier, Broker and Dealer registration, Upper Tier, in force to 12/08/2028 · the recycling note issued 04/05/2026 recording ten waste streams with named carriers · the sustainability note issued 04/05/2026 · the fuel spill response drill of 24/04/2026 · the environmental incident exercise of 21/08/2025 · the annual supplier review of 16/04/2026 covering waste carriers and scrap merchants · the environmental incident position for 2025 and the year to date |
| Site observation | Waste segregation, fuel storage and spill kit provision, at the yard and on site |
| Interview | The Site Supervisor on what happens to waste from a job and what he would do on a spill; a Director on the environmental obligations the client places on AMWS |
3. Result against each clause¶
| Clause | What the standard requires | Objective evidence examined | Result |
|---|---|---|---|
| 6.1.2 Environmental aspects | Determine the aspects and associated impacts considering a lifecycle perspective, taking account of change, abnormal conditions and reasonably foreseeable emergency situations; determine those with significant impact using established criteria; communicate the significant aspects | Aspects are held at APP_06 with the lifecycle view at APP_15. The aspect set follows the work — waste, spillage and release to land and water, fuel and energy use, noise, dust, water use, material storage and traffic. SOP 9.1 Issue 3 sets the review triggers, including abnormal conditions: assessment is reviewed "after an accident / incident at least every three years" | Conforms |
| 6.1.4 Planning action | Plan to take action to address significant aspects and compliance obligations, integrate the actions into system processes, and consider technological, financial, operational and business requirements | Significant aspects carry operational control in the procedures, and the compliance obligations attaching to them carry into the legal register, which was verified against primary sources on 24/04/2026. The carbon and waste diversion positions carry measured objectives. What is not yet in place across the whole aspect set is a scenario-based test of the emergency arrangements attaching to environmental release, which is the subject of OBS-01 | Conforms — see OBS-01 |
| 8.1 Operational control — waste | Establish, implement, control and maintain the processes needed to meet requirements, establishing operating criteria and controlling the processes in accordance with them | SOP 9.4 Issue 3 states the duty of care position and the consequence of getting the paperwork wrong, which is the control most often treated as administrative: "A WTN that is incomplete or inaccurate is a Duty-of-Care offence." The operating criteria are explicit: "Waste is segregated at source, stored in suitable containers, and only released to a registered waste carrier holding a valid licence." Retention is stated against the statutory period — two years for transfer notes under SOP 9.4, and under SOP 9.5 Issue 3 for hazardous waste: "Retain the producer copy of every Consignment Note and every quarterly consignee return for a minimum of 3 years from the date of consignment (Hazardous Waste Regs 2005, reg 49)." Carrier and receiving-site duties are stated: "Carriers must hold a valid hazardous-waste-carrier registration and the receiving facility must hold an environmental permit covering the relevant EWC code(s)." AMWS's own carrier registration was in force to 12/08/2028, and the ten waste streams with their named carriers were recorded on 04/05/2026 | Conforms |
| 8.1 Operational control — land and water | Control the processes that could cause release to land or water | SOP 9.3 Issue 3 sets quantified storage criteria rather than a general instruction: "That storage is secure and bunded (Bund area to capture 110% of total volume including small containers in vehicles)", and an absolute prohibition where the risk is highest: "Equipment or plant is not re-fueled near drains/water courses." Observed on site at the yard | Conforms |
| 8.1 Outsourced processes and the supply chain | Ensure outsourced processes are controlled or influenced, and determine the extent of control | Waste carriers and scrap merchants are within the approved supplier arrangements and were reviewed in the annual cycle completed 16/04/2026, which recorded that all were rated at the top band with no complaints logged during the review period | Conforms |
| 8.2 Emergency preparedness — environmental release | Establish a planned response to potential emergency situations, and periodically test | Spill kits are carried on every vehicle, which POL_HSQE_10 Revision 3 states as policy: "We maintain spill kits on all vehicles and ensure our teams understand how to respond quickly to environmental incidents." The response has been tested at both levels within the period: practically, at a fuel spill response drill at the depot on 24/04/2026 with the Site Supervisor and two operatives, which passed and led to absorbent stocks being topped up; and by desktop, at an environmental incident exercise on 21/08/2025 covering silt entering a watercourse, at which the regulator notification procedures were confirmed. Testing is examined in full at IA202612 | Conforms — see OBS-01 |
| 9.1.2 Evaluation of compliance | Evaluate fulfilment of compliance obligations at a determined frequency and retain the result | The legal register carries a dated verification of 24/04/2026. The statutory authorisation the environmental duties depend on was produced and in force. The environmental incident position is a nil return for the full preceding year and the year to date, recorded on the accident and incident statistics. The sustainability note of 04/05/2026 records the external position: no environmental nonconformities were raised at the most recent external environmental surveillance audit. Examined in full at IA202615 | Conforms |
4. Findings¶
4.1 Non-conformities¶
None.
4.2 Observations¶
| Ref | Clause | Observation | Owner | Target | Corrective action |
|---|---|---|---|---|---|
| OBS-01 | ISO 14001 8.2 | The emergency arrangements for environmental release are documented, the spill kits are provided and in date, and the response has been tested twice within the period. What is missing is a forward calendar of scenario-based environmental drills. The scenarios worth planning for are specific to the work — a fuel spill on the highway, a hydraulic burst at depth, and contaminated ground discovered during excavation — and a planned annual exercise against each with documented lessons would close the gap between testing that has happened and testing that is scheduled | Sean Ashton and Jason May | 30/09/2026 | CAR-2026-008 |
4.3 Status of the previous audit of this area¶
IA202507 raised an observation on environmental drill scheduling, carried as CAR-2025-011. It is rolled forward into CAR-2026-008 rather than closed. The practical and desktop tests held since that audit are evidence that testing occurs; the calendar the observation asked for has not been produced.
5. Conclusion¶
Environmental management conforms to the ISO 14001 requirements within the scope of this audit. Aspects are determined against the work with a lifecycle view, and the significant ones carry operational control in procedures that state quantified criteria rather than intentions — a bund capacity, a refuelling prohibition, a retention period tied to the regulation that sets it.
The waste position is the strongest evidence in this area. The duty of care is treated as a legal duty rather than as paperwork, the carrier registration is current, the streams are recorded with named carriers, and the carriers themselves sit inside the supplier control arrangements and were reviewed in April. Environmental release has been tested both practically and by desktop within the period, and both tests produced a consequence rather than only a result.
One observation was raised, on the scheduling of future drills rather than on the response arrangements themselves.
6. Recommendations¶
- Set the scenario-based environmental drill calendar and close CAR-2026-008 on the first completed exercise against it, not on the calendar.
- Record each environmental drill in the same testing log as the safety drills rather than in a separate schedule, so one log evidences clause 8.2 for both standards.
- Keep the annual review of waste carriers inside the supplier cycle. It is what ties the duty of care to a dated control rather than to a filed certificate.
7. Sign-off¶
| Role | Name | Position | Signature | Date |
|---|---|---|---|---|
| Auditor | Sean Ashton | HSQE Consultant, Onyx Operations Ltd | S. Ashton | 08/05/2026 |
| Reviewed and accepted | Aaron Mason | Director | A. Mason | 08/05/2026 |