IA202615 — Legal Compliance¶
Audit Record
| Field | Value |
|---|---|
| Audit reference | IA202615 |
| Area audited | Compliance obligations — identification, access, evaluation and cascade |
| Audit criteria | ISO 14001:2015 and ISO 45001:2018 clause 6.1.3, with clause 9.1.2 evaluation of compliance · SOP 3.3 · APP_10 |
| Audit date | 12/05/2026 |
| Auditor | Sean Ashton, HSQE Consultant, Onyx Operations Ltd |
| Auditees | Aaron Mason (Director), Leanne Mason (Director) |
| Result | Conforms. 0 non-conformities, 1 observation |
| Previous audit of this area | IA202515, 2025 cycle |
| Form | FORM_INTAR001 Rev 1 ID 01/09/2025 |
1. Scope, criteria and independence¶
1.1 Scope¶
How AMWS identifies the legal and other requirements that apply to it, keeps them current, evaluates whether it complies, and gets a change in the law to the people who have to work differently because of it.
Clauses examined: ISO 14001 and ISO 45001 6.1.3 compliance obligations, together with 9.1.2 evaluation of compliance, which is where 6.1.3 is tested for effect. Statutory licences and registrations held by the business are examined as evidence of both.
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 3.3 Management of Legal & Other Requirements Issue 3 (01/05/2026) · SOP 9.4 Management of Waste Issue 3 · SOP 9.5 Hazardous Waste Issue 3 · SOP 8.10 Hand-Arm Vibration Issue 3 · SOP 8.12 Confined Space Issue 3 · POL_HSQE_03 Anti-Slavery Revision 3 |
| Registers examined | APP_10 Legal & Compliance Register at Issue 2, with the citation verification of 24/04/2026 |
| Records sampled | The three certificates of registration held with Alcumus ISOQAR, running to 23/11/2027 · the Waste Carrier, Broker and Dealer registration held with the Environment Agency, Upper Tier, running to 12/08/2028 · the Goods Vehicle Operator's Licence OF2049103, Standard National, six vehicles authorised · the minuted management review of 27/09/2025, items 3b and 4.9 · the toolbox talk programme issued 04/05/2026 |
| Interview | Both Directors, on how a change in the law reaches the business and who acts on it |
3. Result against each clause¶
3.1 Clause 6.1.3 — Compliance obligations¶
| Requirement | Objective evidence examined | Result |
|---|---|---|
| Determine and have access to the compliance obligations related to environmental aspects and to OH&S hazards and risks | SOP 3.3 Issue 3 names the instrument and its coverage: "A M Water Services maintains the Legal & Compliance Register (APP_10) covering all health, safety, environmental and quality legislation, ISO/BSI standards and water-industry requirements that apply to AMWS activities, products and services." The register runs to eighty-one requirements across nine domains, each carrying how it applies to AMWS, the controls relied on, a compliance status and a last-assessed date. Access is through the portal, which is the master source for controlled documents | Conforms |
| Determine how those obligations apply, and take them into account in establishing and maintaining the system | Each register entry carries an applicability statement and the control measures relied on, so the register states the duty and the answer to it rather than only citing the instrument. Sampled across all nine domains. The obligations are carried into the procedures that deliver them: SOP 9.4 Issue 3 states the duty of care position — "A M Water Services applies the statutory Duty of Care under Section 34 of the Environmental Protection Act 1990 to all controlled waste it produces" — and SOP 9.5 Issue 3 carries the retention rule to the statutory reference: "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)." | Conforms |
| Obligations are expressed as operating limits where the duty is quantified | Tested on the two clearest examples. SOP 8.10 Issue 3 carries the vibration control values into the procedure rather than leaving them in the register: "Exposure Action Value (EAV) 2.5 m/s² A(8)" and "Exposure Limit Value (ELV) 5.0 m/s² A(8) — Must not be exceeded." SOP 8.12 Issue 3 carries the confined space hierarchy the same way: "A M Water Services applies the Confined Spaces Regulations 1997 hierarchy — avoid entry, risk-assess, control, safe system of work, emergency arrangements." This is the point at which a legal register becomes an operational control rather than a list | Conforms |
| Maintain the obligations — keep them current as the law changes | SOP 3.3 Issue 3 sets both the floor and the live route: "The register is reviewed at minimum bi-annually by the HSQE Consultant; in practice it is reviewed more frequently through the routine HSQE compliance cycle (weekly Director / HSQE compliance calls, monthly Onyx site visits) and on an event-driven basis whenever a regulator publishes an update, a client raises a new requirement, or an Onyx legislation alert lands." The most recent maintenance act is dated and recorded on the register: every citation was verified against legislation.gov.uk and regulator sources on 24/04/2026, and that date is carried on the majority of entries as their last-assessed date | Conforms |
| Other requirements beyond statute are captured | Client framework requirements, ISO and BSI standards and water-industry requirements sit in the register alongside legislation. POL_HSQE_03 Revision 3 carries a non-statutory commitment expressed as a rule: "A M Water Services Ltd maintains a zero-tolerance approach to modern slavery and human trafficking in all forms." | Conforms |
| Changes are cascaded to the people affected | SOP 3.3 Issue 3 defines when a change has to reach the workface, by test rather than by judgement: "A change is 'significant' and triggers a toolbox talk if it changes how field operations are performed, requires new PPE, alters a permit-to-work threshold, or changes a notification timescale (RIDDOR, environmental incident)." The delivery mechanism is the rolling toolbox talk programme issued 04/05/2026, which carries the legal reference against each topic. The cascade reaches operatives at briefing; it does not yet reach someone who joins a site after a briefing, which is the subject of OBS-01 | Conforms — see OBS-01 |
3.2 Clause 9.1.2 — Evaluation of compliance¶
| Requirement | Objective evidence examined | Result |
|---|---|---|
| Establish, implement and maintain the processes needed to evaluate fulfilment of compliance obligations; determine the frequency; evaluate compliance and take action if needed; maintain knowledge and understanding of the compliance status | The evaluation is the dated verification pass recorded against the register on 24/04/2026, combined with the status field carried on every entry. The evaluated position was reported to top management and minuted on 27/09/2025: "Full compliance maintained with all applicable legal requirements. Insurances renewed successfully November 2024. CDM 2015 compliance exemplary. Environmental permits and waste carrier licenses current." and, in the objectives section, "All compliance obligations met for ISO 9001, 14001, 45001. Legal compliance 100%." The review concluded "Legal compliance remains exemplary with zero enforcement actions or breaches." | Conforms |
| Retain documented information as evidence of the compliance evaluation results | The statutory authorisations the business depends on were produced and checked in date at the audit: the three ISO certificates of registration with Alcumus ISOQAR under UKAS accreditation to 23/11/2027; the Environment Agency Waste Carrier, Broker and Dealer registration, Upper Tier, to 12/08/2028; and the Goods Vehicle Operator's Licence OF2049103, Standard National, six vehicles authorised. Each is held on the portal and each was in force at the audit date | Conforms |
4. Findings¶
4.1 Non-conformities¶
None.
4.2 Observations¶
| Ref | Clause | Observation | Owner | Target | Corrective action |
|---|---|---|---|---|---|
| OBS-01 | 6.1.3 with 7.4 | The cascade of legal change works through the toolbox talk programme, which reaches whoever is at the briefing. It does not reach an operative who arrives on a site after the briefing has been delivered, and for the highest-traffic regulatory topics that is the gap. Produce a small number of one-page visual compliance summaries for the yard notice board — service strikes under NRSWA, chlorine handling under COSHH, and RIDDOR reporting thresholds — so the message persists after the briefing | Sean Ashton | 30/09/2026 | CAR-2026-010 |
4.3 Status of the previous audit of this area¶
IA202515 raised the same observation on visual compliance communication, carried as CAR-2025-021. It is rolled forward into CAR-2026-010 rather than closed, because the notice-board summaries have not yet been produced.
5. Conclusion¶
The management of compliance obligations conforms to ISO 14001 and ISO 45001 clause 6.1.3, and the evaluation of compliance conforms to clause 9.1.2. The register is comprehensive across the domains AMWS operates in, states applicability and controls rather than citations alone, and carries a dated verification of every citation against primary sources. The statutory authorisations the business depends on were produced and were in force.
The strength of this area is that the obligations do not stop at the register. Where a duty is quantified, the number is carried into the procedure that governs the work — the vibration action and limit values, the confined space entry hierarchy, the waste retention periods. That is what makes a legal register operative rather than decorative.
One observation was raised, on the persistence of the cascade rather than on its content.
6. Recommendations¶
- Produce the three notice-board summaries and close CAR-2026-010 on the printed sheets in place, not on the drafts.
- Keep the 24/04/2026 verification pass as an annual dated act on the register, so the maintenance requirement at 6.1.3 has a date attached to it each year rather than resting on continuous review alone.
- Continue carrying quantified duties into the procedures rather than referencing the register. It is what an auditor tests when they ask how a legal requirement changes what someone does.
7. Sign-off¶
| Role | Name | Position | Signature | Date |
|---|---|---|---|---|
| Auditor | Sean Ashton | HSQE Consultant, Onyx Operations Ltd | S. Ashton | 12/05/2026 |
| Reviewed and accepted | Aaron Mason | Director | A. Mason | 12/05/2026 |