D05-02d6 ASSESSMENT OF VERIFIERS ON GREENHOUSE GAS EMISSION REPORTS Table of contents 1 PURPOSE .................................................................................................................................. 2 2 EMPHASES OF ASSESSMENT ................................................................................................. 2 2.1 Central location or remote locations ....................................................................................... 2 2.2 Witnessing how verifications are carried out ........................................................................... 3 3 RECORDS .................................................................................................................................. 5 4 EXCHANGE OF INFORMATION ................................................................................................ 5 4.1 Cooperation with verifier ......................................................................................................... 5 4.2 Cooperation with the national competent authority ................................................................. 5 4.3 Cooperation with the competent authority and accreditation body of the Member State ......... 6 5 CHANGES WITH REGARD TO PREVIOUS REVISION ............................................................. 7 6 TRANSITORY PROVISIONS...................................................................................................... 7 7 CONTROL OF THE DOCUMENT ............................................................................................... 7 Revision 1 Effective as from: 30. 08. 2013 Page 1 of 7 Assessment of verifiers on greenhouse gas emission reports 1 D05-02d6 PURPOSE The purpose of this appendix to D05-02 is to determine the scope and manner of assessment specific for assessing verifiers of greenhouse gas emission reports according to SIST EN ISO 14065 and Commission Regulation (EU) No. 600/2012 (hereinafter: verifiers). To this end, the following definitions from Regulation (EU) No. 600/2012 shall be used: “verifier” means a legal person or another legal entity carrying out verification activities pursuant to this Regulation and accredited by a national accreditation body pursuant to Regulation (EC) No. 765/2008 and this Regulation or a natural person otherwise authorised, without prejudice to Article 5(2) of that Regulation, at the time a verification report is issued “verification” means the activities carried out by a verifier to issue a verification report pursuant to this Regulation “EU ETS auditor” means an individual member of a verification team responsible for conducting verification of an operator’s or aircraft operator’s report other than the EU ETS lead auditor “EU ETS lead auditor” means an EU ETS auditor in charge of directing and supervising the verification team, who is responsible for performing and reporting on the verification of an operator’s or aircraft operator’s report. 2 EMPHASES OF ASSESSMENT The assessment refers to the scope of accreditation (Regulation (EU) No. 600/2012, Annex I) in the fields defined in the accreditation application or in the appendix to the accreditation certificate. The assessment of verifiers shall include assessment of the central location of the verifier or remote locations where the key activities and assessment of carrying out the verification within the installation or aircraft operators take place. 2.1 Central location or remote locations During assessment in the central location of the verifier or its remote locations, the assessment team shall, in addition to general assessment techniques, mainly use the following others: review of records, system documents and interviews with the personnel of the verifier, and, if necessary, with an individual verifier. It shall pay particular attention to the following: • status of the verifier and assurance of independence (Regulation (EU) No. 600/2012, Article 42, SIST EN ISO 14065, Clause 5); • appropriate separation of functions of verification/education/testing/control when several of such activities are carried out by the same verifier; • compliance of the quality management system with the requirement of SIST EN ISO 14065 (SIST EN ISO 14065; Clause 12); • monitoring of changes to the requirements for verification; • adequacy of personnel competence criteria (specific for each scope of accreditation, ISO 14066, 4.3), participating in verification processes (for all functions, for example, for the following: review of application, selection of personnel, planning, independent review of reports, decisions, and Revision 1 Effective as from: 30. 08. 2013 Page 2 of 7 Assessment of verifiers on greenhouse gas emission reports • • • • • • • • • D05-02d6 resolutions of complaints) and, as a rule, an interview with the EU ETS auditor is conducted. (Regulation (EU) No. 600/2012, Articles 35, 37, 38 and 39, and SIST EN ISO 14065, Clause 6); procedures for training/maintaining of competence of personnel, in particular the EU ETS lead auditor/auditors, the independent reviewer and technical expert and the monitoring of their work (Regulation (EU) No. 600/2012, Article 35); selection of the verification team (Regulation (EU) No. 600/2012, Article 36) adequacy of the verification, process phases (Agreement; ISO 14064-3, tč. 4.3), planning procedures (Regulation (EU) No. 600/2012, Article 40, SIST EN ISO 14065, Clause 8, and ISO 14064-3); implementation of key activities in remote locations; effectiveness of the control system for locations where critical activities take place, if relevant; carrying out of verifications abroad; control and maintenance of records with a purpose of proving effective carrying out of the verification process. Verification documentation shall include the following: application documents and evidence of application review, report on strategic analysis, working material obtained during a client’s visit and other material used in verification, documentation supporting conclusions in the verification report and verifier statement, verification report with draft opinion, evidence that the report was reviewed by an independent reviewer and that a decision was made, report or statement submitted to a client by a verifier, risk analysis report, etc. (SIST EN ISO 14065, Clause 7.5, and ISO 14064-3); preparation of the verification report and written statement (SIST EN ISO 14065, Clause 8.5, and ISO 14064-3) use of the certification mark. The assessors shall carry out at least three vertical audits of a verifier as part of the initial assessment and reassessments. In their selection, the cases of multi-site organisations, verification processes conducted abroad, initial and control verifications, cases of operators of installations emitting a larger amount of emissions and complex emissions (including process emissions) shall be taken into consideration. Upon regular surveillance visits, at least one vertical audit per individual verification field shall be carried out by taking the above selection criteria into account, and ensuring that all accreditation fields are inspected. In selecting cases for vertical audits, the planned assessments of carrying out verifications shall also be considered to ensure equal representation of the accreditation activity in an assessment sample. 2.2 Witnessing how verifications are carried out To assess how a verifier carries out verification means to establish whether the verification processes are conducted according to the rules, as recorded in the management system of the verifier, and whether the composition of the verification team demonstrates proper knowledge and understanding of verification criteria and has necessary skill and capability for verification or whether the verifier fulfils the relevant requirements of Regulation (EU) No. 600/2012. In selecting the witnessing sample, the complexity of the scope of accreditation, the number of operators and aircraft operators undergoing verification, including how complex these verification are, Revision 1 Effective as from: 30. 08. 2013 Page 3 of 7 Assessment of verifiers on greenhouse gas emission reports D05-02d6 the number of the EU ETS auditors and the EU ETS lead auditors and their verification experiences, as well as the number of personnel participating in the verification process, the training procedures for verifiers, the stability of a verifier, etc., shall be considered. In planning the witnessing, it shall also be considered that the representative number of personnel carrying out verification is taken in the sample and the share of verifications carried out abroad is also taken into consideration. Within the initial assessment and reassessment of the verifier, the representative part of the verification or at least the verifications within two operators or aircraft operators shall be witnessed. One of the viewed verifications presents verification of the operators of installations emitting a large amount of emissions and complex emissions (including process emissions); in case aviation is included, it shall be witnessed separately. Before the witnessing of verification takes place, the verifier shall submit a report on preliminary verification, the verification programme with information on the verification team and verification locations, description of the operator’s or aircraft operator’s organisation, and other materials, for example, the monitoring of the greenhouse gas emissions plan, greenhouse gas emissions permit, decision on emission coupons, and report on strategic and risk analyses. The assessor shall assess the submitted documentation, and adjust the assessment accordingly. In witnessing/assessing of the verification team, the assessor shall carefully monitor the following: • work/cooperation of the members of the verification team (including observers, translators, etc.), management of the team (management of changes to the plan); • manner of contacts with the client (initial meeting (its content), closing meeting (its content and participant list), and management of unpredictable situations); • knowledge of the verification requirements (individual requirements for verification of diverse installations), processes and techniques (verification of monitoring methodology, method of sample selection, verification of control over data, tracing the data, etc.); • capability of acquiring material evidence (suitability of posed questions and focus on important requirements); • understanding and knowledge of requirements from the EU ETS Directive and supportive documents, • competences of verifiers to analyse the correctness of data, on the basis of which the greenhouse gas emission report was compiled. Such a verifier shall have experience in the area of processes that produce emissions and experience and knowledge (training) in the area of assessment/control of data and of bookkeeping principles. • knowledge of national requirements for verification and reporting, knowledge of requirements for competence of the client’s staff); • harmonisation of diverse positions on findings and record of all disagreements; • reporting on findings (correct establishment of a finding, while the inconsistencies shall not be reported in the form of possibilities for improvement; a finding shall be linked to criteria and evidence); • duration and adequacy of the verification programme (relevance of locations and coverage of the scope). Within two weeks following the conclusion of the carried out verification witnessed by the SA assessors, the verifier shall submit a report to SA, prepared for the management of the audited organisation. The assessment team shall prepare a report on witnessing the verification (form OB0543), which will include information on the assessment of the subsequently sent report. Special Revision 1 Effective as from: 30. 08. 2013 Page 4 of 7 Assessment of verifiers on greenhouse gas emission reports D05-02d6 attention should be paid to the content of the verification report and written statement (SIST EN ISO 14065, Clause 8.5, and ISO 14064-3). During witnessing of the verification, the assessors shall assess the operation of the entire verification team. The assessors shall notify the members of the verification team about the results of verification witnessing immediately after witnessing verification within the operator or aircraft operator, if possible. 3 RECORDS Each assessor shall keep records on the conducted assessment in the form of checklists (Form OB05-xx) in a way that both, the scope and method of assessment of individual elements of the system according to the requirements of the relevant standard and guidance for verifiers, and possible general findings, special notes and reference to established non-compliance, are evident. It is especially important that the sector of carried out vertical audit is precisely determined (e.g. verification activity or installation). A mandatory appendix to the professional assessor’s checklist is also Form OB05-43, i.e. Report on Witnessed Verification. The Report shall be prepared separately for each witnessed process. Once the accreditation process is completed, SA shall issue an accreditation certificate with an appendix covering the scope in which accreditation terms and conditions were met. The information on the Member States in which the verifier is carrying out verification and other information (Regulation (EU) No 600/2012, Article 75) are kept within vertfiers records and are publicly available on request. 4 EXCHANGE OF INFORMATION 4.1 Cooperation with verifier The verifier shall, in accordance with Article 76(1) of Regulation (EU) 600/2012, by 15 November of each year, send the following information - the planned time and place of the verifications for next year, - the address and contact details of the operators or aircraft operators whose emissions or tonnekilometre reports are subject to its verification. The verifier is obliged to report all changes to the verification plan promptly. 4.2 Cooperation with the national competent authority In accordance with Article 70(1) of Regulation (EU) 600/2012, SA shall, by 31 December of each year, make available to the competent authority, i.e. the Ministry of Agriculture and Environment (hereinafter: MKO) the following information: - the list of accredited verifiers - the SA work programme for the accreditation of verifiers. The work programme shall contain information on implementation of surveillance/reassessment of the accredited verifier’s work by SA, including the dates of anticipated witnessing verifications, address and contact data of the Revision 1 Effective as from: 30. 08. 2013 Page 5 of 7 Assessment of verifiers on greenhouse gas emission reports D05-02d6 installation operator where witnessing shall take place, anticipated time and place of verifications (also for verifications in other Member States) carried out by the verifier and information on whether SA has required the national accreditation body (NAB) of the Member State in which the verifier is accredited to perform control activities. This information refers to each verifier separately. Subject to Article 70(3) of Regulation (EU) 600/2012, SA shall, by 1 June of each year, make available to MKO the management report for the previous period of one year. The management report shall at least contain the following information in relation to each verifier: - details on newly granted accreditations for verifying reports on greenhouse gas emissions and scope of accreditation, - possible changes to the scope of accreditation for accredited verifiers, - summarised results of surveillance/reassessment activities, - summary of possible extraordinary assessments, and reasons for which they were initiated, - information on complaints filed against the verifier and actions taken by SA. SA shall also make the report available to competent authorities of the Member States in which a verifier carries out the verification activity. 4.3 Cooperation with the competent authority and accreditation body of the Member State In case the accreditation of a verifier is suspended or withdrawn, SA is obliged to forward this information to MKO, relevant competent authority and NAB in the Member State in which the verifier carries out verifications (Regulation (EU) 600/2012, Article 71). In accordance with Article 49(5), the accreditation body of the Member State that has accredited the verifier may request that SA carry out surveillance of the verifier accredited in the Member State when the verifier is performing verifications in Slovenia. In this case, SA shall make an agreement with the accreditation body of the Member State on the manner of surveillance and if surveillance is carried out, report the results of surveillance to the accreditation body that has accredited the verifier (Regulation (EU) 600/2012, Article 73(1). The same applies in case SA requests the carrying out of surveillance of an SA accredited verifier when the verifier is performing verifications in another Member State. In case SA receives information by the foreign accreditation body that the verifier, accredited by SA is not meeting the requirements of Regulation (EU) 600/2012, it shall take appropriate action (Regulation (EU) 600/2012, Article 73(2)), and shall inform the accreditation body that has forwarded the surveillance report (Regulation (EU) 600/2012, Article 73(3)). In case SA shall grant accreditation to a verifier that is not established in Slovenia, SA shall also forward the information referred to in point 5.1 to the competent authority of the Member State in which the verifier is established. In exchange of information with interested parties, it shall use the reporting templates available on the website: http://ec.europa.eu/clima/policies/ets/monitoring/documentation_en.htm Revision 1 Effective as from: 30. 08. 2013 Page 6 of 7 Assessment of verifiers on greenhouse gas emission reports 5 D05-02d6 CHANGES WITH REGARD TO PREVIOUS REVISION / 6 TRANSITORY PROVISIONS / 7 CONTROL OF THE DOCUMENT A valid document shall be located in i4 (SA Information System). A clean copy shall be published on SA's website, and shall be accessible in printed form at the SA Head Office. Printouts and copies of the document shall be informative in nature and shall not be considered to be controlled copies. The validity of these documents should be checked in i4 or on the SA website. Revision 1 Effective as from: 30. 08. 2013 Page 7 of 7