Audits and the Good news – Bad News – No News Comparison – My opinion based on 30 years of EHS audit experience.

Good news from audits is really no news for management. Good news from audits means that things are going as planned and there is no need for management intervention. System effectiveness has been confirmed through the audit process.

Bad news from audits is actually good news for management! The audit findings give management the opportunity to act (create incentive for change). Hopefully that change will correct the bad news situation discovered during the audit.

No News is Bad News. Organizations not performing audits have no means to assess the effectiveness of the management system. They are not getting information feedback about the organizations EH&S performance.

I encourage organizations to continue to audit even if they struggle to correct all the problems discovered. At some point the light bulb will turn on and the organization will recognize they have a problem with the corrective action process and hopefully figure out a fix.

ISO 14001 and Shared Operational Permits.

Sometimes organizations share environmental permits with other organizations.  

This is a common situation with many large industrial operations where several plants are contiguous, use a common wastewater treatment facility or obtain energy from other parts of the organization where it is generated. The key is to carefully define the Scope of the EMS to only include those activities that are under the direct control of the organization implementing the EMS.

One of our clients in the paper industry has a similar situation. They are leasing a portion of a large paper making complex to make something called paperboard. Portions of the leased property are covered under the landlords Tier 1 NPDES Storm Water Discharge Permit and addressed in the SWPPP. The landlord has stipulated in the lease agreement that our client needs to comply with the terms of the SWPPP and we incorporated the conditions of the SWPPP that apply into the EMS as an “other requirement”.

The organizations is certified by an ANAB accredited Certification Body which has accepted our interpretation of the SWPPP as an “other legal requirement”. Again the real key here is to carefully define the Scope of the EMS (4.1) to limit it to the physical areas and process that the organization can control.

Also see – 4.3.1 a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence …..

NASA Kennedy Space Center – ISO 14001 Internal Auditor Training

OV-104 in Flight (NASA Photo)

Recently we delivered an internal auditor training course at the Kennedy Space Center (KSC) near Orlando, Florida. The two day ISO 14001 Internal Auditor course was delivered to a group of 17 NASA employees and KSC contractors. The classroom was within walking distance of the enormous Vehicle Assembly Building, the tallest one story building in the world.

We had a few hours before and after the course and the NASA folks gave us a wonderful behind the screens tour of the Orbiter Service Building where we were able to walk around directly beneath the Orbiter Atlantis (OV-104) as it was being serviced after its recent mission (STS-135). We also visited the Vehicle Assembly Building where the Orbiter Endeavor (OV-105) was being prepared for transport to the California Science Center. Apparently Atlantis is to remain at the KSC in “partial readiness” to fly again, which was the buzz around KSC during our visit. We also got a tour of the recently constructed LEED Platinum Certified NASA Propellants North building which has received several awards for its design.

Endeavour at VSB 10/24/2011

The training course we developed and delivered was specially designed to incorporate the elements of EO13423 and the KSC EMS documentation. The two day training helped refresh NASA internal auditor understanding of effective methods for performing value added process audits. The wide variety of processes and potential environmental impacts at KSC make internal auditing of the NASA operations and contractors especially challenging.

We are planning another trip to KSC to perform Phase II of the training. This phase will involve students participating in an actual internal audit at KSC. This 2 day process based EMS audit will demonstrate process audit techniques and coach NASA internal auditors in planning, implementing and reporting phases of effective internal audits

Here is a link to more information on our Internal Auditor Training courses.