Case: The organization records third-party transport vehicles using the “Outsourced Transport Provider and Site Vehicle Register” (P-E07-01), but its environmental management procedure does not define when to use the form, who checks the information or what controls apply. Records exist, yet the procedure does not provide a traceable basis for managing outsourced vehicles or collecting related emissions data.
In this case, “4.6” is an internal procedure section, not an ISO 14001 clause. The source materials use both P-EO7 and P-E07; verify whether the character is letter O or zero and standardize the controlled document code before use.
Outsourced vehicles may create environmental aspects such as exhaust, noise, idling and traffic, and may supply greenhouse gas activity data. Requirements for inspection documents, access restrictions or other controls depend on applicable law, contracts, site risks and authority requirements. A single case should not be treated as a universal legal rule.
Audit focus
If the procedure does not say who completes the register and when, who verifies vehicle information, how nonconforming situations are handled and how records are retained, the organization may not be able to show that the form is used consistently. The gap can also separate contractor management, pollution prevention and data collection into unrelated activities.
Trace a real entry to determine how the provider is approved, who verifies the vehicle, what instructions site staff follow, how exceptions are addressed and how data are retained under the organization's inventory boundary and method. Whether this constitutes nonconformity depends on applicable requirements and objective evidence.
1. Root-cause analysis
- Outsourced mobile sources were omitted during procedure revision. The procedure focused on organization-owned vehicles, while environmental-aspect identification or contractor controls did not address third-party transport vehicles.
- The form was not linked to its parent procedure. P-E07-01 existed, but the procedure did not define its scope, completion timing, review responsibility, exception handling or retention.
- Contractor environmental controls were incomplete. Vehicle environmental criteria were not clearly integrated into procurement, contracts or site-access controls, so registration did not become effective risk control.
- Document review did not check consistency. When the form was created or revised, reviewers did not compare it with the procedure, assigned roles and actual practices.
2. Immediate correction and current controls
First confirm applicable duties and site risks, then use proportionate interim controls:
- Issue a controlled interim instruction that defines covered vehicles, entry checks, responsible contacts, exception handling and record retention. Before requesting an emissions inspection certificate, confirm that the requirement applies to the vehicle and site.
- Review current transport providers and recent site entries; complete missing vehicle details, provider information, check dates and applicable evidence or validity dates, and flag items awaiting confirmation.
- For vehicles that do not meet applicable law, contract terms or site rules, take an authorized response such as pausing entry, requesting contractor correction or arranging alternative transport. Retain the basis and records of the decision.
- Start revising the environmental management procedure to include the form's purpose, roles, checking timing, escalation and records.
3. Corrective and preventive actions
- Revise the procedure. Add outsourced mobile-source controls to internal section 4.6 or another appropriate section. Define provider qualification, vehicle information, site checks, periodic review, exception handling and records, with an explicit link to P-E07-01.
- Include environmental terms in contractor management. Based on law and organizational risk, state vehicle requirements, evidence to provide and responses to violations in new or renewed contracts, contractor instructions and entry rules.
- Set an operable review process. Assign an environmental or contractor-management contact to review vehicle data and validity dates according to entry frequency and risk, and to follow exceptions through closure.
- Check document alignment. When adding or revising environmental forms, confirm that the parent procedure describes purpose, responsibilities, use timing, related records and retention.
- Include the controls in internal audits. Sample contractor lists, vehicle registrations, site implementation and exception records, then assess whether controls remain effective.
4. Greenhouse gas data boundaries
Vehicle emissions classification depends on organizational boundary, operational control, transport direction and the service relationship. Fuel burned by vehicles owned or controlled by the organization is generally treated as direct emissions under its chosen inventory method. Emissions from purchased third-party transport may fall under GHG Protocol Scope 3, Category 4 (upstream transportation and distribution); downstream delivery of sold products may need Category 9 assessment. ISO 14064-1 uses direct and indirect emission categories and does not itself name them “Scope 3.”
P-E07-01 can support collection of vehicle and service information, but the register alone cannot determine the emissions category or calculation. Define boundaries, activity data, methods and data owners under the selected inventory standard and retain traceable evidence.
5. Suggested audit evidence
| Audit area | Evidence to review |
|---|---|
| Procedure and form link | Current controlled procedure, P-E07-01, revision history and form instructions |
| Contractor management | Provider list, contract or environmental notices, qualification and communication records |
| Vehicle entry controls | Vehicle register, entry checks, applicable evidence, spot checks and exception records |
| Roles and competence | Responsibility assignments and training for gate, warehouse and environmental staff |
| GHG data | Inventory boundary and category decisions, transport activity data, calculation basis and data-quality checks |
| Effectiveness | Internal-audit results, finding follow-up, later samples and management review |
6. Confirming effectiveness
Do not close the finding only because section 4.6 was added or the form was completed. Sample different providers and dates to confirm complete records, staff understanding and appropriate handling of exceptions. Trace a GHG activity-data item to confirm its classification, calculation and source under the chosen method. If practice still differs from the procedure, revisit root causes and controls.
Summary
Environmental procedures, forms and site practices should agree. Managing outsourced vehicles requires clear applicable requirements, responsibilities, exception handling and record purpose—not only an entry log. Linking these controls to contractor management and correctly handling transport emissions data under the inventory boundary helps provide coherent audit evidence and reduce recurrence.