XM, a chain of 25 petrol stations, established an EMS following the requirements of ISO 14001, which was third-party certified 10 years ago. You are…

The auditor's primary concern is a potential non-compliance with a legal requirement. The EMS Manager's justification for the missing inspection certificates is based on a verbal conversation, which does not constitute objective evidence. According to the evidence-based approach, a core principle of auditing (ISO 19011), the auditor must seek verifiable proof. ISO 14001:2015 (Clause 9.1.2) requires the organization to retain documented information as evidence of its compliance evaluation. Therefore, the most logical next step is to inquire about written confirmation from the authority, as this would be the necessary objective evidence to verify the claim and close the potential non-conformity.

A. This question diverts from the immediate issue of a potential legal non-compliance to a future environmental aspect (waste management), which can be audited later.
B. The contract with the inspector is irrelevant to why three legally required inspections were not performed and why there is no evidence of an official exemption.
D. This question focuses on future operational planning, whereas the auditor must first address the current and unresolved potential non-compliance with existing regulations.

1. ISO 14001:2015, Environmental management systems — Requirements with guidance for use.

Clause 9.1.2 Evaluation of compliance: This clause states, "The organization shall retain documented information as evidence of the compliance evaluation result(s)." The auditor is correctly seeking this documented evidence, which is currently missing. A verbal agreement does not meet this requirement.

Clause 6.1.3 Compliance obligations: The organization must determine how its compliance obligations apply. A verbal waiver represents a change in this application that requires verification.

2. ISO 19011:2018, Guidelines for auditing management systems.

Clause 4, Principles of auditing, point (d) Evidence-based approach: "Audit evidence should be verifiable... The evidence-based approach [is] the rational basis for reaching reliable and reproducible audit conclusions in a systematic audit process." The auditor's question (C) directly follows this principle by seeking verifiable evidence instead of accepting an unsubstantiated verbal claim.

3. PECB. (2022). ISO 14001 Lead Auditor Training Course Material.

Day 3, Module: Audit Procedures, Section: Collection and verification of information. The training material emphasizes that auditors must collect sufficient and appropriate audit evidence. It specifies that verbal statements should be corroborated with other forms of evidence, such as records or documentation, especially when related to critical areas like legal compliance. The question about written confirmation is a direct application of this verification principle.