RINA 1. SCOPE AND OBJECTIVE 2. FIELD OF APPLICATION 3. REFERENCES 4. DEFINIZIONI VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES

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1 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPTCERTI-LCA di SCOPE AND OBJECTIVE This instruction defines the modality of verification of the LCA of products and services of an Organization, according to ISO 14040:2006 e ISO 14044: FIELD OF APPLICATION This instruction is applied to all the Operative Units of Services S.p.A. (). 3. REFERENCES IAF MD 6:2009 Application of ISO 14065:2007 Rules for the validation and verification of greenhouse gas assertions IS-QPTCERTI-LCA-01 Qualification and relative maintenance of the personnel involved in the verification process of LCA studies of products or services of an organization. 4. DEFINIZIONI CAR: Non Conformity or Request of corrective action CCPLS: Sustainability & Food Certification Compliance Unit Formatted: Font: Bold CDM: Clean Development Mechanism CFP: Carbon footprint CL: Request of clarification CPC: Central Product Classification DM: Decision Maker. Person or group of people that take a decision in connection to the certification. EPD: Environmental Product Declaration ETS: Emission Trading System Reasonable assurance: a high but not absolute level of assurance, expressed positively in the verification opinion, as to whether the operator s or aircraft operator s report subject to verification is free from material misstatement (source: Regulation EU ETS 600/2012) GHG: Gas a effetto serra GS: Gold Standard GVI: Audit team ITR: Independent Technical Review ITRP: People involved in the independent technical review LCA: Life Cycle Assessment OPN: Operative Network Programme related to GHG: System or voluntary or compulsory scheme, international, national or subnational that registers, accounts or manages the emissions, removals or increase of the GHG removals outside the organization. QI: Informative questionnaire, document filled in by the Organization, containing all the elements useful for the preparation of the offer QPT: Sustainability, Environment & climate change sector R: Recommendation Scheme Manager (SM): Responsable for the management of the specific scheme

2 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPTCERTI-LCA di 15 File Manager (RPC): Responsible for the administrative-managerial aspects of the file (i.e. Contract Review preparation (Application Reviewer (AR)), audit team assignment (Program Reviewer (PR)), preparation of the LCA certification proposal) and qualified on the basis of the requirements established in instruction IS-QPT CERTI-LCA-01. (Note: During the start-up phase of the scheme, in the case of operational offices which don t have a file manager, QPT CCPLS as scheme manager or a delegated person will provide the necessary support). Formatted: English (United States) Materiality: Concept that individual or an aggregate of errors, omissions and misrepresentations could affect the results of the impact categories analyzed in the LCA. VCS: Verified Carbon Standard WFP: Water footprint CONTROL OBJECTIVE. The control objective is the reason for the existence of the control, expressed in simple words. CONTROL AND RESPONSIBILITY. Control is the activity necessary to obtain, with reasonable confidence, the achievement of a goal. 5. RULES The activities related to the verification process of LCA are shown in the flow chart in point 6.1. Surveillance activities are not foreseen. If a client wishes to update the LCA study, a new verification will be carried out according to the methods described in the following paragraphs. 6. DESCRIPTION OF THE PROCESS AND THE ACTIVITIES 6.1 FLOWCHART FOR THE VERIFICATION OF THE LCA STUDY PHASES Sequential stages Moving from one stage to another Decisions are represented by rhombuses. The rhombus divides the original flow into 2 flows; the main one focuses on achieving the final result while the secondary one comprises one or more phases that must be completed before returning to the main flow. The column headings indicate the operational responsibilities of the phases shown in each column. Each phase is placed in the right column in relation to the responsibility assigned. The flow chart is to be read in conjunction with Table 6.2. Each phase or decision shown in the flow chart is numbered so as to relate the flow chart to table 6.2; the latter gives a detailed description of each phase, defining responsibility, input, output, critical factors and records.

3 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPTCERTI-LCA di 15 MAIN PHASES OF THE VERIFICATION PROCESS OF PRODUCTS AND/OR SERVICES CLIENT/ ORGANIZATION CLIENT/ ORGANIZATION SM/RPC SM/RPC AUDIT TEAM AUDIT TEAM ITRP (COORDINATED ITRP BY (COORDINATED SM) BY SM) DM DM SENDING IQ 1 PREPARATION OF THE OFFER 2 ISSUE OF THE OFFER OFFER ACCEPTED? NO END YES 3 ORDER ACCEPTED YES 3 CONTRACT SIGNED NO 4 TEAM ASSIGNMENT DOCUMENTS SENDING 5 DOCUMENTAL REVIEW 6 PREPARATION OF THE AUDIT PLAN 7 ON SITE VISIT 8 PREPARATION OF THE DRAFT REPORT 9 PREPARATION OF THE REPORT 10 INDEPENDENT TECHNICAL REVIEW END NO ITR OK? DOCUMENTS OK? 11 PREPARATION OF THE STATEMENT YES 12 FINAL DECISION 13 DOCUMENTS SENDING AND CLOSURE OF PROCESS * The on site visit can be waived in particular cases as described in this instruction below.

4 4 di DESCRIPTION OF THE MAIN PHASES OF THE PROCESS OF VERIFICATION OF THE LIFE CYCLE STUDIES OF PRODUCTS OR SERVICES 1 PREPARATION OF OFFER 2 ISSUE OF THE OFFER RPC or SM RPC or SM IQ filled in by the client Offer prepared The Scheme Manager or one of its delegate or a RPC, perform the following activities: - analized the IQ and the data needed for the preparation of the offer - checks availability of resources and competences to carry out the verifications in the right time - calculates the cost of the verification, taking into account the actual verification time in man/days (according to the table in par. 7) - draws up the offer. The QPT CCPLS person responsible or the RPC checks and signs the offer. SM or the OPN office sends the offer to the client. -offer prepared - Offer signed by authorised personnel - Offer sent to the organisation - The information needed to draw up the offer is to be clearly defined in the informative questionnaire Only authorised personnel can sign the offer. - Recording of potential client s data in ANACLI, CAI-C -Form: LCA_IQ filled in by the client -Form: LCA_OFFER filled in by Form CONTRACT REVIEW (form: LCA_CR) - Offer signed by authorised personnel (head of the operational office or QPT CCPLS person responsible) 1 Input: Evento iniziale di una fase 2 Output/Obiettivo: Risultato della fase, motivo per il quale la fase si attiva

5 5 di 15 3 CONTRACT STIPULATION SM or RPC - Verification request on form or organisation s order The scheme manager (SM) or his/her delegate examines the request/order to check it is in line with the offer sent. If it is not, he/she contacts the organisation for clarification. The OPN secretariat or SM or his/her delegate records acceptance of the offer in CAI-C. -Request/Order complete and in line with the offer -Contract stipulated between and the organisation -Request for documents related to the LCA study - Request/Order complete and in line with the offer -Contract opened in CAI-C -Verification request filled in and signed by the organisation or order - Confirmation of acceptance form SM or his/her delegate or RPC checks and signs the Confirmation of acceptance. The OPN secretariat or SM or his/her delegate sends the Confirmation of acceptance to the client containing the contract number and the request for the documents needed to verify the LCA study: -LCA study report -calculation excel sheets The calculation excel sheets can also be viewed during the on site visit at the discretion of.

6 6 di 15 4 DEFINITION OF TEAM SM or RPC organisation contract SM or his/her delegate or RPC selects one or more technicians for the verification and informs the organisation of the name(s) which may object to them. The technical personnel must be qualified according to instruction IS-QPTCERTI-LCA-01, they must be independent of the verification activities and at least one member of the team must be qualified as team leader. The team, whether one or more people, must have at least one team leader qualified according to IS-QPTCERTI-LCA-01. At least one member of the team must be qualified for the CPC code (2 digits) of the product/service to be verified. In the absence of personnel qualified for the LCA with qualification in the pertinent CPC code (2 digits), suitable personnel may be included to cover the pertinent macro sector, as established in paragraph 11 of this instruction. - Verification team defined and communicated to the client - Independence and qualification of the verification team. - The technical expert is not to undertake verification activities without the presence of a Team Leader. Communication of team to the organisation. Formatted: English (United States)

7 7 di 15 5 DOCUMENTAL REVIEW - Verification team Documents relevant to LCA study sent by the organisation: a) LCA study b) calculation sheets (optional, verifiable on site) The team examines the documents to ensure they meet the verification criteria of the LCA standards. Any findings arising from the document review are to be reported in the draft verification report so the organisation can make the necessary amendments to the documentation. When the number and seriousness of the findings arising from the review are such that they could invalidate the successful outcome of subsequent phases and the team believes that it is necessary that the organisation makes the amendments before the verification can continue, the outcome of the document review is communicated to the organisation during this phase. The Team Leader can avoid the on-site verification provided that: - all evidences needed for the assessment has been sent by the organisation to the verification team (calculation sheet, windows of the software used for the LCA analysis, characterisation factors used and their allocation in the software, sufficient number of informative questionnaires and/or documents of evidence for the source of the primary data collected by the company or at its suppliers). -Communication of the outcome of the documental review to the organization (at discrection of the team) -Documentation examinated -Findings coming from documental review - The document review can be performed offsite or on site (it is necessary to specify whether it s performed on or off site). - The organisation may be asked to provide other documents and additional information or, if necessary, to make corrections or changes to the documents provided before verification activities continue. - Document review outcome communicated to the organisation (at the team s discretion) (dispatch of LCA_DR_REP) The on-site verification cannot be avoided if one of the impact categories analyzed have a value for the production process of the site of the organization (process of production of the final product final assembling of the product) is higher than those derived from the other phases analysed (upstream and downstream processes). 6 - Verification team Document Verification plan -Form: LCA_PLAN filled in by

8 8 di 15 PREPARATION OF VERIFICATION PLAN 7 ON SITE VISIT 8 PREPARATION OF DRAFT REPORT (offsite) review carried out - Verification team - Verification plan sent to the organisation -Verification team - LCA_DR_REP after the on site -Subsequent control action taken -On-site verification performed At least 1 week before the verification date, the team leader: -prepares the verification plan which clearly describes the activities to be carried out at the organisation and the people to be interviewed; -agrees on the verification date with the client; -sends the verification plan to the client. The team verifies on site: - system boundaries, inclusions, exclusions, cut-off; - functional unit; - data collection and assessment of data quality; - input/output; - supply of raw materials; - transport; - allocation; - characterization factors used; -sensitivity analysis, uncertainty, interpretation of results (if required by the standard); - use phase and use profile, if relevant; - end of life, if relevant; -that the data and information related to LCA are reliable and that there is evidence to support the emissions calculated and included in the LCA report (informative questionnaires, bills of materials, databases used, data quality and source, invoices, documental evidence, etc...); - that the final LCA datum is correct and suitably expressed. The team draws up the draft verification report summarising the findings which are to be resolved by the organisation before completion of the verification activities. The findings are categorised as sent to the organisation -Useful evidence of on-site verification to draw up the report. -List of interviewees. Draft verification report - It s necessary to trace the data to find omissions or errors of transcription and recalculate the emissions and formulas on the calculation sheets to confirm the calculations. -Take note of the allocation method used and of double counting. -Check that all processes and corresponding input and output have been included and that the exclusions are justified and acceptable. -Attention to the allocation method used and the double counting. -Verify that are included all processes and the corresponding inputs and outputs and that the exclusions are justified and acceptable. -Non conformities or Corrective Action Requests (CAR): noncompliance with one or more requirements of the reference standard, with other requirements related to the LCA assertion or missing the verification team Information to be inserted in the report (evidences of the on site visit useful for the drawing up of the report, list of the interviewed etc.) Form: LCA_REP filled in by the Team Leader without final conclusion on compliance with the verification requirements.

9 9 di 15 9 PREPARATION OF REPORT (offsite) --Organisation/ Verification team/ local OPN/QPT CCPLS office -Organisation s Documents amended and replies sent to verification team nonconformities, also called Corrective Action Requests (CAR). The report can also contain Requests for Clarification (CL) or suggestions for improvement in the form of Recommendations (R). The table 2 of the verification report is provided to the organisation for further clarification or to enable the organisation to make the necessary amendments to the documents related to the LCA report. The organisation sends its replies to the findings and the amended documentation following the findings. On receipt of the replies and amended documents, the team revises the draft verification report, including the organisation s replies and the team s comments in relation to each finding. If all the findings have been satisfactorily resolved in the team s opinion, the team includes in the report the final conclusion on compliance with the verification requirements. Otherwise, the team re-sends the draft verification report (just table 2) to the organisation having updated the status of the findings. If the findings are not satisfactorily resolved and accepted by : - after 3 months from the issue of the first draft verification report, or - there are more than 3 revisions, QPT CCPLS has the right to terminate the contract or to proceed with the issue of the final report and a negative verification statement. The Team Leader sends the report to the Scheme Manager. The Scheme Manager or his/her delegate Final verification report prior to the independent technical review documentation of data and information related to the LCA. -The report can be relevant to more than one product/service. -The findings are to be concluded clearly in the report -A statement (positive outcome) means that the statement of emissions does not contain material errors, whereas a negative verification statement indicates that the information is not in compliance with the specific requirements. Form: LCA_REP Verification Report - final draft report Formatted: English (United States)

10 10 di INDEPENDENT TECHNICAL REVIEW Team Leader/Scheme Manager/ITRP -IQ -Contract review, -Request of the client, -Audit plan, - Verification report final draft report - LCA certification proposal prepares the certification proposal of the verified LCA. The Scheme Manager or his/her delegate sends all the documents to the technical personnel authorised to perform the independent technical review (IS-QPTCERTI- LCA-01). The ITRP checks the following aspects: -verification of verification team competency; -decision on acceptance of task and time required (contract review); -verification plan; -verification outcome proposal; -adequacy of documentation for internal assessment; -elements highlighted by the verification team if they led to a negative assessment; -any incorrect information and any errors corrected during the verification; - clarification requests, recommendations or corrective action requests (CAR) clearly resolved in the report and their correct classification. The ITRP fills in the independent technical review form (LCA-ITR), adds any comments and signs it. If comments have been made, depending on their type and competency, either the TL or Scheme Manager replies in the appropriate space. The ITRP comments are to be transposed by the team. Following the positive outcome of the independent technical review, ITRP sends the final verification report, together with the LCA- ITR and the certification proposal, both signed LCA_ITR with comments from the ITRP dealt with by the verification team sent to the Scheme Manager LCA_REP after ITR final Competence and independence of personnel that performs the independent technical review LCA_ITR filled in, dated and signed by ITRP. LCA_REP final after ITR

11 11 di STATEMENT PREPARATION 12 FINAL DECISION 13 SEND DOCUMENTS CLOSE PROCESS Scheme Manager -Final report after ITR QPT CCPLS Sector Manager (DM) Scheme Manager -Final verification report -Verification statement Final verification report - Statement of compliance with final approval date, to the Scheme Manager. The DM countersigns the certification proposal. The Scheme Manager or one of his/her delegate after having controlled the presence of the documentation, the positive outcome of the independent technical review and the certification proposal countersigned by the DM prepares the declaration of a verification containing the following information: - name, address and other relevant information related to the organization; - references to products/services; - date and revision number of the LCA study; - quantification of the values of the impact categories subject of the study; - conformity with the criteria/requirements of verification of the standard against which has been performed the audit; - Any limitations; - The date and the verification statement; - Authorized signature (Head of QPTCCPLS). The DM is the QPT CCPLS Sector Manager. The Scheme Manager or his/her delegate submits the final verification report and the statement to the QPT CCPLS Sector Manager for signature. The QPT CCPLS Sector Manager approves and signs the statement and the final verification report and sends them to the Scheme Manager. The Scheme Manager or his/her delegate sends the approved final verification report and the statement to the organisation. The Scheme Manager or his/her delegate files Verification statement -Final report approved and signed by the DM -Verification statement approved and signed by the DM - Final report approved and signed by the DM is sent to the organisation Progressive numbering of the statements Verification (LCA_CD) Statement - Final report approved and signed by the DM - Verification statement approved and signed by the DM

12 12 di 15 signed by the MD a copy of the statement. - Verification statement approved and signed by the DM is sent to the organisation

13 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPT CERTI-LCA CALCULATION OF MAN/DAYS The total time, in man/days, is shown in the table below. The values given in the table are purely for reference and may be reduced or increased, justifying the reasons in the contract review form. LCA FACTORS THAT COMPLEXITY INFLUENCE THE COMPLEXITY LOW =2,5 6 MEDIUM =6-9 HIGH > 9 MANDAYS MANDAYS MANDAYS Number of products / 1 product >1 and <5 >= 5 services subject of LCA Complexity of the products Simple product (few Product quite complex Complex product (high / services materials, very low (fair number of number of number of materials and materials and components) components) components) Service with high number Service with fair of activities concerned Service with few number of activities whose environmental activities concerned whose impacts are reported environmental impacts are reported Differences among -- Similar products / Different products / products/services verified services (changes services (changes > +- within +- 10% among 10%) the values of the impacts categories of one product with another one) System boundary From cradle to gate From cradle to grave From cradle to grave Precision of the Presence of a Presence of a Absence of a management procedures for data certified management management system system collection, filing and system management Type of addressee of the Internal Public 3 Public 3 LCA study Comparative assertions Absent Absent Absent The intermediate situations (i.e. elements which come under different complexity classes) will be managed according to an intermediate number of man/days among the complexities. Discounts up to a maximum of 40% can be foreseen in case of audits combined with the EPD scheme. Discounts up to a maximum of 20% can be foreseen in case of audits combined with the CFP or WFP scheme. In the case of LCA updating verifications of products/services already verified in the past (in previous years), it is possible to avoid the on-site verification and to consider a discount in terms of man/days also as concerns document assessment activities up to a maximum of 50% of the man/days foreseen for the first verification. The on-site verification, in the case of multisite organisations, is performed where final assembly of the product is carried out. In the case of LCA service verifications, the on-site verification will be performed at one of the sites where the service subject to verification is provided. 3 An LCA is considered to be public when it s made available on a website open to everybody or when it is done a printed publication to be available to everybody. It s not to be considered public the LCA study realized in a Business-to-Business communication either the ones published on the website available to a limited number of people. The organization is not to be considered responsible of any copies of the LCA study that would be spread by third parties to which the organization has given the LCA study. Formatted: English (United States)

14 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPT CERTI-LCA-00 To the man/days reported in the table above has to be added a 0,25-0,5 man/day for the ITR activities. 8. CARRYING OUT VERIFICATION ACTIVITIES The team is required to assess the contents of the reporting, data, in terms of collection method, source, quality, representativeness and the calculations made to reach the final values of the impact categories for the products/services subject of analysis. The team will have to confirm or not, based on the verifications made, the final values of the impact categories analysed within the LCA calculated by the Organization for the product/service analysed. A negative verification statement indicates that the information does not comply with the specific requirements. 9. DATA SAMPLING On the basis of the information obtained and documentation received, the Team Leader will establish the data sample to be verified, consisting of a 25% random sample of the data to be sampled and the remaining part (60%) will be defined in relation to: Errors and/or the need for further investigation/clarification identified during the document assessment; - Phase with the greatest impact (i.e. upstream, core or downstream processes) and consequent processes which determine the major impacts within the impact categories analysed; - Data collection (i.e. where there is a good data collection system which makes it possible to have reasonably correct primary data, the sampling need be less extensive than in situations where the data collection system is based on approximation and without control points during data collection). The modality of sampling performed by the TL on the basis of the elements above, will be reported and described in a proper paragraph inside the audit report. 10. MATERIALITY Following the checks made, the verification team is to have reasonable assurance that individual or an aggregate of errors, omissions and misrepresentations will not significantly affect the final data of the impact categories analysed in the LCA. 11. COMPOSITION OF THE VERIFICATION TEAM The verification team is to consist of the following personnel: - One person qualified as Team Leader for the LCA in accordance respectively with the requirements of instruction IS-QPTCERTI-LCA-01; - One person who knows the local language and in which the documentation to be verified is written; - One person competent in the CPC code of the product/service to be verified. The audit team can be also composed of just one person provided this person including the requirements of the requirements reported above. Alternatively to what reported above, can also be applied the following combinations for the LCA audits: - A team leader ISO or EMAS or EU ETS or CDM or VCS or GS or ISO with the CPC code of an organization and a technical expert or an LCA co-teamer; - A team leader ISO or EMAS or EU ETS or CDM or VCS or GS or ISO and a technical expert or an LCA co-teamer with the CPC code of the organization; - A LCA team leader with a co-teamer ISO or EMAS or EU ETS or CDM or VCS or GS or ISO with the CPC code of the organization. It is necessary for the above combinations to include an interpreter if the local language is not known.

15 VERIFICATION OF THE LIFE CYCLE OF PRODUCTS OR SERVICES IS QPT CERTI-LCA-00 Where on-site verification time is only one man/day and does not have a person available to cover all the above requirements, the additional person included to cover one or more of the above-mentioned requirements will be at the expense of and will not be included in the man/days charged to the client. 12. COMPOSITION OF THE VERIFICATION TEAM IN CASE OF COMPARATIVE LCA TO BE MADE PUBLIC AVAILABLE In case it has to be performed a verification activity of comparative LCA studies to be made public available, the verification team, except what reported inside the paragraph 11, shall be composed of at least 3 members, aside from the Team Leader. Inside the team, at least a person shall be an expert in the scientific frameworks relevant for the impact categories most important of the study, besides other experts in other frameworks relevant to the impact categories analysed. The final outcome of the verification together with the final audit report shall be included in the LCA study.