EMAS verifiers - Introduction

In accordance to EMAS concept, those organizations which got registered in the system are periodically verified by neutral and credible environmental verifiers. Environmental verifier checks EMAS functioning and confirms that environmental statement contains true data. During the first verification, the environmental verifiers check if:

  1. organization conducted the initial environmental review and identified direct and indirect environmental aspects (compliance with Annex VI and VII of EMAS Regulation)
  2. internal environmental audits comply with requirements of Annex II of EMAS Regulation
  3. environmental management system complies with requirements of Annex IA and IB of EMAS Regulation
  4. organization complies with legal requirements and other regulations related to environmental protection
  5. organization’s environmental statement complies with requirements of Annex III of EMAS Regulation

If all the requirements are met, the verifier validates environmental statement which is an EMAS registration application attachment submitted by organizations to the voivod (competent body). Organizations have to update the environmental statement annually, so the verifier is involved in that process every year. Moreover, EMAS regulation requires to perform the verification of the system at least every 36 months. In most of the cases, verification audits are performed every year together with validation of environmental statement. There is an exception for small organizations. In the case of significant non-compliance of the environmental management system or environmental statement, verifier is obliged to immediately inform the relevant competent body, i.e. the voivod who registered the organization. In certain justified cases, the verifier should also inform the relevant authorities about non-compliance.

Polish Center for Accreditation (PCA)

The role of the Polish Center for Accreditation who is responsible for accreditation of verifiers, is to check all necessary competences of EMAS verifier candidates, provide accreditation and supervise the work of verifiers, all in accordance to EMAS Regulation and legal act dated 30th of August 2002 on system compliance (Dz.U. Nr 166 poz. 1360 including further changes).

In Poland there is possibility to accredit either institutional verifiers (EMS certifying units) or individual verifier. The EMAS verifier candidate should fulfill requirements set in Environmental Verifiers Accreditation Program (system EMAS).

The EMAS verifier candidate should demonstrate relevant higher education background (engineering, economy, law or other in the field of environmental protection) and relevant working experience concerning environmental protection or/and environmental management systems. Each candidate verifier must take part in the exam organized by PCA.

In the process of accreditation of both institutional and individual verifiers competencies are evaluated. For final evaluation note the following elements are considered:

Candidates who fulfills all requirements and passed the test are given PCA accreditation certificate. Environmental verifiers operates just within the scope of their accreditation. For institutional verifiers the accreditation is valid 4 years while for individual verifiers without time limits (when the criteria of EMAS Regulation is fulfilled). Accreditation certificate is the basic document, which shall be put forward to the Minister of Environment in order to be signed on the list of accredited EMAS verifiers. The application template with the signing on the list of accredited verifiers request was described in Annex 1 to Minister of Environment Regulation dated 23rd of April 2004 on the application template for being placed on environmental verifier list and documents templates, forms, terms of transferring information from the regional (voivodship) to the national registry. (Dz. U. 2004 Nr 94, poz.930).

Verifiers while EMAS verifying process and environmental statement validation, shall evaluate organization performance in a objective and independent way. Verifiers can not be commercially, financially or in any other way related with the organization.

Verifiers through approving environmental statement, confirms and assures that its content is reliable. Supervision of PCA on individual verifiers is realized through documentation review e.g. Quality Book, notes taken during verification process review and even review of approved environmental statements or eye witnessing their performance at the clients place (not less than once a 24 months). PCA supervision on institutional verifiers is realized through monitoring of verifiers at certifying unit clients and similarly to individual verifiers by management system documentation review, notes taken during verification process review and even review of approved environmental statements (not less than once o 12 months). Scope for institutional verifier can be widen to other branches after submitting documents proving availability of competent team. Limitation of accreditation scope takes place when competencies for auditing certain branch is expired. Scope of accreditation for individual verifier can be widen in case of achieving competence in other branch. Suspending accreditation both for institutional and individual verifier is the issue when none accreditation during 24 month is not performed. Renewal of verifier accreditation is after eye witnessing of a verifier. Minister of Environment after being given information by PCA has legal right to take the verifier out of the list or suspend verifier activity.

The environmental verifiers accredited in one of the EU Member States, before performing verification activities in Poland, have to inform PCA with 4 week notification period about such an intention. The foreign verifier has to provide evidence on knowing Polish legal requirements and having ability to communicate in Polish. If such documents are not submitted 4 weeks in advance, PCA has legal right to request for verification date change. Representative of PCA takes part during audit and eye-witnesses foreign verifier.

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