We were recently honored with appointed to the United States Technical Advisory Group on to ISO 50001 – Energy Management Systems Standard. We are helping develop and represent the US position on important guidance that is currently under development and will be discussed by TC 242 in Dublin, Ireland April 30- May 4th.
Here Come the Bean Counters!
Having lead hundreds of sustainability performance assurance engagements over the last several decades I admit bias but have seen first hand evidence that organizations exaggerate and in some cases misrepresent their sustainability performance. This is especially true when the marketing departments are tasked with the job of turning an organization green.
As non-financial sustainability performance information is relied upon to make important decisions about investment and other business relationships, assurance of organizations sustainability performance assertions will become more common. An important question is who will do this assurance work? Recognizing opportunity the financial accounting profession is hard at work tooling up to fill this emerging niche http://www.ifac.org/publications-resources/ifac-sustainability-framework-20
The confidences stakeholders can place in the results of an assurance engagement are directly proportional to the competence of those performing the audits. It will be interesting to see how the bean counters do at assessing environmental, health, safety and social performance as they endeavor to to learn the practice in this market.
Gap Assessment and Internal Audits
If you are doing a Gap Assessment I would start at the top of the standard and march right through it clause by clause. Use the EMS manual as a reference and make sure all elements of the standard have been addressed.
If you are planning an internal audit I would consider using a process approach where you audit many of the clauses almost simultaneously in each department or functional area of the organization. The following is an example of a line of questioning you might consider when you are interviewing employees in a Maintenance Department (MD).
Auditor: What are some important environmental aspects of the maintenance department?
MD: We clean and paint equipment used in the mine so we generate solvent waste and we have air emissions from the spray paint operations.
Comment: If the aspects match those on the record required by 4.3.1 you have some evidence of conformance to 4.3.1 and 4.4.2. If you see parts cleaning operations and painting operations being performed but these have not been identified as environmental aspects you may have nonconformity to 4.3.1. If these aspects have been identified but the MD representative you interview has no idea about what an aspect is or any of the impacts from parts cleaning or painting you may have nonconformity to 4.4.2.
Auditor: How do you make sure that waste solvents are handled properly?
MD: There are some important laws we must comply with for these waste solvents and we follow our Waste Solvent work instruction.
Comment: You now have some evidence that they have identified the legal requirements 4.3.2 and have established operational controls of significant aspects 4.4.6.
Auditor: This section of the Waste Solvent work instruction says the waste solvent storage area will be inspected weekly and the results recorded on the inspection sheet. Can you show me a record of the inspection that was performed 2 weeks ago?
MD: Sure here it is.
Comment: With this question you are looking for evidence of Operational Control 4.4.6, Monitoring and Measurement 4.5.1, Internal Audit 4.5.5 and Record 4.5.4. You could even get Corrective Action 4.5.3 if problems are found during the inspections which were corrected.
Auditor: Can you tell me about what you do if you see a fire somewhere in the facility
MD: We have been trained in proper use of fire extinguishes so if I think I can put the fire out I will try. No matter what, I will call the designated emergency coordinator who will follow-up and I will evacuate to my designated assembly area in the parking lot across the street.
Comment: Here is evidence of 4.4.7 and 4.4.2 and maybe 4.4.3.
The potential audit trails you can follow in a department are almost endless and each trail should be able to give you evidence for one or more clauses of the standard.
ECSI Assurance Trademark Approved!
Hurray!! ECSI Assurance Trademark Approved! Here is link. US tradmark_112211
We also cleared the last pre-application hurdle and should begin the ANSI ASQ National Accreditation Board application review and approval process within the next few weeks.
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.
The Future of ISO as a Measure of EH&S and Sustainability Performance
Over the past few years I have been watching the development of various corporate sustainability reporting initiatives such as GRI (Global Reporting Initiative) and financial industry indexes such as Dow Jones Sustainability Indexes. Recently the Prince of Wales has weighed in on the issue with the development of an initiative to promote something call Integrated Reporting.
I have been trying to assess whether the criteria used in these newer measures of performance are on a path to eclipse the ISO standards or if the ISO standards will become an important part of these reporting and indexing products especially the assurance parts. I sometimes wonder if a parallel assessment process with its own set of performance criteria is coming that will make the ISO standards obsolete and with it the certification body accreditation process IAF and ISO certification business.
What are your thoughts? Is ISO gaining credibility as a measure of an organizations performance or are the common myths we hear about ISO so deeply entrenched and stakeholder confidence eroded to the point that the world is likely to seek other methods to assess organizations performance rather than ISO and IAF.
Tips For Environmental Aspect Identifcation
Most organizations embarking on the EMS implementation process greatly underestimate the level of competence needed to do a good job in identifying environmental aspects, impacts and deciding which are significant. It’s sort of like landing an airplane. If you have never done it before the outcome can be a disaster.
The result of inept aspect identification will inevitably be an ineffective EMS. Do yourself and your organizations a favor and get professional help from someone who has done it many times. There are a zillion mediocre EMS consultants that will charge much and deliver little. Do your home work and check their references before you invest in their assistance.
Also, there are serious drawbacks to using a risk based approach to determining which environmental aspects are significant. A better outcome and more effective EMS will be achieved by establishing significance criteria (filters) for aspects such as:
1. Is the aspect regulated?
2. Is there potential for a significant impact from an unplanned release?
3. Are their other interested parties that care about the aspect like neighbors?
4. Is it costing lots of money to manage the aspect?
5. Is the scale or duration of the impact such that we should manage the aspect?
If an aspect is found to meet one of the criteria (gets caught on one of the filters) it should be considered significant or important to the organization and managed by the EMS (controlled, improved or both). If it passes all of the filters it should be considered insignificant or irrelevant to the organizations and ignored by the EMS.
Wisconsin Green Tier – Benefits and Risks to Wisconsin Business
The following is a brief discussion of the Wisconsin Department of Natural Resources (WDNR) Green Tier program and some of the benefits it can have for business in Wisconsin and those doing business with WDNR Green Tier companies. The article also discusses some of the potential risks to these same business and WDNR that may result from stakeholders loosing confidence it what the Green Tier logo is supposed to mean.
Benefits to Business
A few months age I met with Pat Stevens who had just begun his new position as the Administrator of the Wisconsin Department of Natural Resources Division of Air and Waste. I was particularly interested in the potential changes to the Green Tier Program with a new administration and WDNR Secretary. During our discussions, Pat said he believed the new secretary and the new administration would continue to support and try to expand the Green Tier Program. One of the areas we explored was how Wisconsin businesses, in general, perceive the program and how the WDNR can gain broader acceptance with businesses by making some improvements.
I told Pat my experience had been that many potential Green Tier participants believe the benefits of the program do not justify the investment of effort needed to apply to the WDNR and become accepted into the program. I told him that we have also heard from some businesses that they perceive Green Tier participation as potentially increasing the risk of regulatory agency oversight and fines rather than reducing burdensome regulatory oversight.
Pat and I discussed a few ideas about how the WDNR can generate interest in the program through incentives, such as streamlined air emission construction permits for new or modified major sources and reduced reporting burdens. Within the last several weeks I have been pleased to see that a Tier 2 contract with Serigraph and correspondence with 3M in Prairie Du Chien ,WI included provisions for streamlined air permitting as Pat and I had discussed. I believe this is a move in the right direction and should help improve businesses perception of the potential benefits of Green Tier program.
Risks to Business and WDNR (Green Wash)
Pat and I also discuss what I perceive as significant potential risk to business participating in the Green Tier program and WDNR itself. The risk is that the process used by WDNR to confirm the existence of an ISO 14001 EMS may not be sufficiently robust to prevent some organizations acceptance into the program that are not really committed to the effective operations of the EMS. These participants want to be able to fly the Green Tier flag as evidence they are superior environmental performers but they are not actually committed to continual environmental performance improvement through an EMS.
This issue is particularly important for Tier 2 participants who may be receiving significant benefits under the green tier contracts. An example of this potential risk can be seen in WDNR acceptance of Serigraphs claim to be ISO 14001 “certified” as the basis for acceptance in to the Green Tier Program.
Although Serigraph has claimed to be certified to ISO14001 a examination of credentials of the Certification Body (Verysis, LLC) that issued the ISO 14001:2004 Certificate to Serigraph indicates that this organizations is not accredited by ANAB (the internationally recognized accreditation body in the USA) or any other International Accreditation Forum member. The accreditation of Verysis issued by an organization with a similar name “International Accreditation Board” but does not reference any internationally recognized critera used to evaluate Verisys Registrars.
Here in the USA ANAB accredited ISO 14001 registrars undergo and extensive evaluation of their certification and audit process to ensure that they conform to the requirements of ISO/IEC 17021 Conformity assessment — Requirements for bodies providing audit and certification of management systems. There is no evidence that Verysis has undergone such an assessment.
The Wisconsin Statute for the Green Tier program describes what WDNR needs to consider when determining the acceptability of Green Tier audit in § 299.83 (7a) as follows:
7m)?Environmental auditors. The department may not approve an outside environmental auditor for the purposes of sub. (3) (d) 4. or (5) (c) 2. unless the outside environmental auditor is accredited by an accreditation body that complies with standards of the International Organization for Standardization for accreditation bodies or meets criteria concerning education, training, experience, and performance that the department determines are equivalent to the criteria in the standards and guidance of the International Organization for Standardization for entities providing audit and certification of environmental management systems.
The basic problem is that unless WDNR does at good job of reviewing the qualifications and objectivity of the auditors performing Green Tier audits there is a significant risk that at some point unqualified auditors will be performing Green Tier audits and issuing certificates of conformance to organizations that do not deserve them. If these Green Tier participants are later found to not be the superior performers that WDNR claimed them to be there is significant potential for stakeholders to loose confidence in the meaning of the Green Tier logo. This would result in embarrassing times for both the WDNR and all the other Green Tier participants.
I am interested in your feedback on this issue. Do you think additonal incentives are need to increase Green Tier participation and is WDNR doing a good job of screening who should be admited to the Green Tier program. Please post a comment if you are so inclined.
Kevin Lehner, EMS-LA
President ECSI