Last Updated on November 24, 2025 by Melissa Lazaro

Why Understanding Non-Conformities Matters

If you’re working toward ISO 14001 certification or preparing for a surveillance audit, one of the smartest steps you can take is understanding the most frequent audit findings. I’ve reviewed and supported dozens of ISO 14001 audits across different industries, and the same patterns keep showing up—regardless of company size, sector, or experience level.

Most non-conformities aren’t caused by complicated technical failures. They usually come from gaps in consistency, missing evidence, or systems that look good on paper but aren’t fully implemented on the floor.

In this guide, you’ll learn:

• The most common ISO 14001 audit findings.
• Why those findings occur.
• How to prevent them using simple, practical actions.
• Real examples showing how they appear during an audit.

If you address even half of these before your audit, you dramatically improve your outcome.

Weak or Incomplete Aspect–Impact Assessment (Significance Methods & Controls Gaps)

This is one of the most common findings in audits. Often, organizations create an aspect register once and never update it again—even when operations or legal requirements change.

Auditors look for:

• A clear method for determining significance.
• Evidence of updates when processes change.
• Controls aligned with significant aspects.

For example, I once reviewed a system where hazardous waste disposal was clearly listed as a significant aspect—but there were no operational controls listed or implemented. That created an avoidable finding.

Pro Tip:
Review your aspect register annually—or whenever you add new chemicals, equipment, or processes.

Common Mistake:
Treating the aspect register as a one-time exercise instead of a living document.

Poor Compliance Evaluation and Legal Register Management (Tracking Requirements & Updates)

Legal compliance is another common audit weak point. Many organizations can list applicable laws—but can’t prove how they’re monitored or evaluated.

Auditors expect:

• A documented legal register.
• Evidence of monitoring regulatory updates.
• Compliance evaluation records.
• Corrective actions when needed.

One organization I supported had operating permits and environmental reports—but they weren’t linked to the compliance register. The system existed, but there was no evidence of control—resulting in a non-conformity.

Pro Tip:
Assign one clear owner for legal and regulatory updates, not a “shared responsibility.”

Common Pitfall:
Compliance tracking happens informally—emails, verbal updates—but nothing is documented.

Missing or Weak Internal Audits (Surface-Level Findings or No Evidence Review)

Internal audits should simulate the certification audit—not just tick boxes. Weak internal audits almost guarantee findings in Stage 2.

Auditors check whether your internal audit:

• Evaluated the EMS against ISO requirements.
• Reviewed evidence—not just process descriptions.
• Identified gaps honestly.
• Included corrective actions and follow-up.

Pro Tip:
Interview employees and review site controls—not just documents—during internal audits.

Common Mistake:
Internal audits show “no findings” every year. That’s not a strength—it’s a red flag.

Incomplete or Ineffective Management Review (Missing ISO-Required Inputs & Outputs)

A management review must show leadership engagement and strategic oversight—not just meeting minutes.

It should include:

• Trends in environmental performance.
• Compliance status and legal updates.
• Internal audit results.
• Risks, opportunities, and required resources.

When auditors see a one-page record saying “Everything OK,” it signals the system isn’t being used fully.

Pro Tip:
Use your KPIs and internal audit results as discussion triggers—not just reporting.

Common Mistake:
No recorded follow-up action or decisions—meaning the review didn’t drive improvement.

Insufficient Competence and Awareness Evidence (Employee Interviews & Training Records)

Even if everything looks perfect on paper, your employees must demonstrate understanding during interviews. Auditors often ask operators simple questions like:

• “What environmental risks are linked to your job?”
• “What do you do if there’s a spill?”

If the person hesitates—or points to wrong controls—it becomes a finding.

Pro Tip:
Keep the message simple. Employees don’t need clause numbers—they need clarity.

Common Mistake:
Signed attendance sheets used as proof of competence—without demonstrating actual understanding.

Missing Monitoring Data or Poor Performance Tracking (KPIs Without Evidence)

Organizations often set environmental objectives—but forget the follow-through. Auditors want to see how you:

• Verify progress.
• Adjust actions when targets aren’t met.
• Use data to improve—not just report.

A company once listed “Reduce electricity use by 10%” as an objective—but didn’t have baseline data or measurement records. Great intention, but compliance failure.

Pro Tip:
Track indicators monthly or quarterly—not just before the audit.

Common Pitfall:
Objectives don’t align with significant aspects—so they feel unrelated to the EMS.

Weak Operational Controls or Poor Site Conditions (Mismatch Between Documents and Reality)

This is where most findings show up: the site walk.

Auditors check whether actual conditions match documented controls.

Common onsite findings include:

• Missing or unclear labels.
• Incorrect waste segregation.
• Poor spill kit readiness.
• Missing signage or PPE instructions.

Pro Tip:
Conduct a mock walk-through with your aspect register in hand.

Common Mistake:
Relying only on procedures—without checking physical implementation.

Documentation Control Issues (Outdated Versions, Unclear Ownership, Unapproved Changes)

Documentation errors often seem small—but they compromise system credibility.

Auditors look for:

• Version control.
• Ownership and approval records.
• Removal of obsolete documents.
• Controlled access.

A classic example: a printed recycling instruction taped near a workstation—outdated by two revisions.

Pro Tip:
Keep one single source of truth—don’t allow parallel systems.

Common Mistake:
Local teams save their own copies resulting in multiple versions.

FAQs: ISO 14001 Audit Non-Conformities

1. Are minor non-conformities normal?
Yes. Most certification audits include some minor findings. The key is how quickly and effectively you respond.

2. Which findings can fail an audit?
Major non-conformities—especially those tied to legal compliance, risk controls, or systemic issues.

3. How long do we have to close findings?
Typically 30–90 days depending on the certification body and severity.

Conclusion: Turn Findings into Improvement—not Anxiety

Understanding the most common non-conformities gives you a real advantage. When you know what auditors look for—and what causes findings—you can act before the audit, not after.

The strongest ISO 14001 systems evolve through honest review, evidence-based actions, and continuous improvement—not perfection.