Here is a senario and question that was posted to a Linkedin group that I thought was interesting.  Below are my thoughts.

Senario – An auditor was performing a site visit to the management offices during an ISO50001 audit in a factory. The time was noon and the weather was hot outside. and he noticed that a large area of the offices from the east side was subject to a direct sunlight. The curtains are already there but they look in a bad status and when he asked staff there it seems never been used to cover windows. He checked then the EnMs records and found that the SEUs are only the cooling and the motors. He checked the operational procedure , nothing is mentioned about use of curtains. The list of ECMs does not mention anything about the use of curtains. Can he consider this as a non-conformity? and according to which clause of ISO50001?

My Reply –

There is no way in heck that a competent auditor should write a NC to ISO 50001 based on the facts provided here.  Much more information is needed to make that call.  I would want to know at least the following:

1.  Has the organization established objectives and targets associated with the cooling SEU?  If not this is a clear NC to 4.4.6.  If they have established objective and targets for this SEU then I want to know…

2.  Have they established action plans for achieving these objectives and targets?  If not, it is also a clear NC to 4.4.6.  If they have established action plans for achieving the objectives and targets then I want to know…..

3.  Have the action plans been sufficiently developed that the curtains should have been considered as an effective operational control?  If the conclusion to this question in “No” the action plans have not been sufficiently developed,  I need to decide if I believe a creditable effort has been put forth by the organization given the timeframe the actions plans have been in place.  If the action plans have been in place for a few years and little progress has been made to identify and implement controls than a NC to 4.4.6 is justifiable.

If on the other hand the organization has recently implemented the EnMS and the objectives and targets have only been in place for a few short months, I cannot expect them to have made great progress on identifying appropriate controls yet.

4. At some point on this audit trail I also want to ask myself the question…Is this a “material issue”.  In other words “does it matter” in the grand scheme of the organizations EnMS if these curtains are in use or not.  This is auditor judgment and why auditors should become certified or otherwise competent to do this important work.  Depending on the circumstances this might be the first questions I would want to ask.