In consultation with the organization, the environmental verifier develops a program to ensure that all the elements necessary for EMAS registration are verified in a period not exceeding 36 months.
This provision aims to guarantee to the management of the organization and to the interested parties that the policy, management system, procedures, information, measurement and control of data in the environmental field comply with the provisions of the EMAS Regulation.
Continuous communication between the verifier and the organization contributes to improving the credibility of the EMAS system and the trust of its users. In order to guarantee constant monitoring of the organization's environmental performance and management system, it would be advisable to organize the verification so that it concerns one third of the organization's activities every year, so that over the thirty-six months envisaged as the maximum period all the activities are subject to verification.
Such a practice will also increase the verifier's confidence in the accuracy, credibility and reliability of the information contained in the environmental statement.
However, in small organizations or small businesses, the audit can be carried out in a single visit, with a periodicity to be agreed between the verifier and the organization, but which in any case includes a visit to the entire system every 36 months.
The verifier establishes and agrees the verification program only after completing the complete verification and initial validation of the environmental declaration. When establishing the verification program, the verifier must take into account the following factors:
- effectiveness and credibility of the internal audit program, in particular the frequency of internal audits;
- complexity of the environmental management system;
- environmental policy;
- size, scale and nature of the organization's activities, products and services;
- importance of the direct or indirect environmental aspects of the organization, which it controls or could
- soundness of the data and information management and recovery system, as it is connected to information
and the data contained in the environmental declaration;
- precedents regarding environmental problems;
- scope of activities subject to environmental regulations;
- results of previous verifications;
- experience of the organization in applying the provisions of EMAS.
In assessing compliance with the provisions of EMAS standards, the verifier can base his assessment on the functions, activities, products and services offered by the organization, or alternatively on the environmental aspects on which the organization exercises directly and / or indirectly the its control and its influence.
The verification relating to organizations with ISO 14001 accredited certification (or any other environmental standard) in accordance with the EMAS Regulation procedures, may only invest items not covered by the recognized standard.
In such cases, the verifier must take into account the ISO 14001 surveillance program in establishing the verification programs and, if possible, try to combine the evaluation visits, to avoid unnecessary repetitions and an unnecessary waste of time and resources on the part of the organization. However, the verification activities will differ from those relating to surveillance visits carried out under the ISO 14001 certification.