Category Archives: EHSMS Audits

Disappointing News from ANAB

Posted on by

In late spring we meet with ANAB at their headquarters in Milwaukee to kick off the process of becoming an ANAB accredited registrar. Our hope was to issue ISO 14001, OHSAS 18001 and ISO 50001 accredited certificates to business in the upper Midwest.  To our surprise during that meeting ANAB made it clear that consultancies are prohibited from accreditation as certification bodies.  In ANABs eyes consultancies and anyone involved in governance of a consultancy is incapable of impartiality when performing ISO certification assessments.

We continue to believe that consultants make good auditors and vice versa.  The financial audit sector (accounts) has operated successfully for many decades using the model to ensure competency of both auditors and consultants.  We believe that ANAB, IAF and ISO’s conclusion that the threats to impartiality by consultancies are irreconcilable is not based in fact.  We also believe that the threats of financial self-interest by ANAB accredited certification bodies are at least as potent as any threat to impartiality from a consultancy performing certification activities.  This is because accredited CBs can (or should) only be allowed to generate revenue from one source, their certification activities.

We remain committed to trying to work with ANAB to find a way to offer ISO certification services in the upper Midwest but for the time being have placed this lower on our priority list of objectives.

Here Come the Bean Counters!

Posted on by

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

Posted on by

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.

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

Posted on by

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.

The Future of ISO as a Measure of EH&S and Sustainability Performance

Posted on by

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.

Internal Audit Teams

Posted on by

Many organizations greatly underestimate the investment of resources needed to perform effective EHSMS internal audits.  The result is almost always a confused audit team which conveys a confused implementation effort to the rest of the organization.  The organization, including top management then looses respect for the EMS which can take years to overcome.  Don’t make this common mistake. 

 

If you are a team leader invest in your own competence by taking a certified EMS-LA course which includes an evaluation of your competence to lead audit teams.  Then invest in training a team of internal auditors in the requirements of ISO 14001 and ensure they understand the relationship between audit criteria, audit evidence and audit findings,  Lastly, make sure all the auditors poses the important personal attributes like being able to discuss without arguing, being able to listen effectively, good note taking and being perceptive.  Once you have covered those bases you are ready to lead a good internal audit that can provide important information upon which top management can act.

Wind Turbine Production and ISO 14001/OHSAS 18001 Management Systems

Posted on by

This turbine is at the top of a 300 foot tower. The garage door at the back is about 15 feet tall. There are electric motors in the hub that control the pitch of the propeller blades for optimal performance. Click to enlarge

About 60 percent of what we do at ECSI is internal and third party audits.  Every so often we do one that is very special.  Last year it was for the US Department of Energy at Argonne National Labs.     Recently, we performed a combined ISO 14001 and OHSAS 18001 Stage 1 and Stage 2 registration audit on behalf of one of our registrar clients for a fascinating company located in east central Iowa that assembles, tests and installs wind turbines.

Wind power is a growing business as you can see by driving around the countryside these days. When I first began planning for the audits I knew that the facility was only making the power generating part of the complete wind system.  So I was thinking … how complex can this be?  They probably purchase the generators and then bolt on a few pieces of hardware to attach it to the tower and blades.   Holy mackerel was I in for a shock. 

As I was walking through the facility on the way to the Stage 1 opening meeting,  I was stunned at how huge and complex these turbines are.  The turbines are assembled in three sections (gear box, hub, and base) that will be put together on top of the tower in the field.  The castings that make up the housings for the gear box, hub, and base, are gigantic, each weighing close to 30 tons.  Once assembled, the gear box alone weights almost 50 tons and they were moving these around with cranes and gantry cranes.  Obviously the operational controls for ensuring safe lifting were an important part of the OHSAS portion of the audit.

Turbine Parts - Click to enlarge

The gear box, base, and hub castings come from Germany and need to be cleaned and painted with the associated significant environmental aspects.  Large gears that transfer the wind energy from the blades to the generators need to be micro finished in an oversized vibratory deburring process.  This increases the life of the gears to around 20 years.  Replacing the gears if they fail is an expensive proposition because it needs to be done at the top of a 300 feet tower.

The assembled generators are also tested to confirm they are capable of generating the promised 2640 KW and 1320 VDC.  Generating that kind of energy in a testing environment requires special controls, training, and competence to be done safely.

The audit process was enhanced by management’s commitment to the system.  They recognized the value of the audit process in ensuring a return on their EHSMS investment.  Employees  also helped us collect the evidence we needed to support our recommendation for registration.  We are proud to have been a part of this developing technology and industry that is helping to reduce international environmental impacts of electrical energy generation.

Approach to QMS Registration Audits

Posted on by

 One of the registrars we audit for has asked us to respond to a few questions posed by a potential audit client.   Each question (in bold font) is followed by our response (in italic font).  Feel free to share your thoughts here in a comment. 

(1)      Which one or two areas of the Quality Manual (of the 8 required areas) does your registrar focus  heavily on during the initial certification audit and why?

We view the Quality Manual as a road map to the QMS.  It describes the core elements of the QMS and provides direction to related documentation.  We use this Manual to help us understand how the QMS operates.  The Manual is the point of departure while we go about the work of collecting objective evidence to show that the organization is meeting the requirements of ISO 9001:2008.  Therefore, the Manual itself is not the focus of our process approach to auditing.  Rather, we use it to point us to the evidence of conformance that we need to observe and record during the audit.  We do not treat any areas of the Manual as priority.  We use the Quality Manual more for navigation of the QMS to help us find the evidence we need to determine the QMS effectiveness at enabling continual improvement.

(2)      Which one or two processes of the required six does your registrar focus heavily on during the initial certification audit and why?

All of the QMS processes are important; thus, during our assessment of an organization’s QMS, we focus on all processes, not just a few.   If any of the elements of the QMS are absent (unless design is legitimately excluded,) the system will not be effective. It is therefore imperative to view the QMS as a whole when drawing a conclusion about both its effectiveness and its conformance to ISO 9001:2008.

 More mature and ready organizations initially focus their attention on the following areas when implementing and registering a QMS:

 8.2.3 Monitoring and Measurement of Processes

 Organizations should identify the key performance indicators that they use as metrics of the performance of the organization’s QMS.  We like to explore these metrics to understand why the organization chose them, how the measurements are made, and how the results of the measurements are conveyed to management.

 8.5 Improvement

 The ability of an organization to solve problems is another area we like to explore.  What are the processes used to solve problems?  How does the organization investigate problems so they understand causality?  Although organizations are not required to do so by ISO 9001:2008,  we like to investigate to what degree they have embraced formal problem-solving techniques like 5Y, 8D, Lean Six Sigma, or others.

 An organization’s ability to solve problems is key to continual improvement. However, during an initial audit, it is sometimes difficult to find much direct evidence of the effectiveness of these techniques.  Evidence of the effectiveness of the organization’s problem-solving techniques becomes clearer with time, as the organization works through correcting nonconformances or customer-related issues. 

Green Tier Audits, Stakeholder Confidence, and Business in Wisconsin

Posted on by

Recently, we were privileged to address the Green Tier Advisors on the difference between the Green Tier audit process and other internationally accepted processes for certifying conformance of an organizations EMS.  A copy of the presentation handout is posted at the WDNR Green Tier website (  http://dnr.wi.gov/org/caer/cea/environmental/advisors/documents/20100917powerpoint.pdf)

The purpose of our presentation was to ask the Green Tier advisors to consider important questions three important questions as follows:

1.  Is the Green Tier audit process adequate to assure stakeholders (citizens, WDNR and others) a reasonable level of confidence that the superior environmental performance claims by participants are valid?

2.  Why is there a gap between what the international community considers to be adequate EMS audits and what has been the practice in Wisconsin for Green Tier audits.

3.  Should WDNR be endorsing unverified claims of superior environmental performance made by Green Tier applicants?

Ideally we would like to try to stimulate some discussion here about these questions to help WDNR and the Green Tier advisors as they consider if enhancing the Green Tier audit process would be beneficial or if the audit process is adequate as it is.  You are encouraged to participate in the discussion and can do so anonymously or contribute representing yourself or your organizations. 

We intend to make additional related postings here shortly to flesh out these issues and provide information and resource to help interested parties better understand the questions. 

You are also welcome to call us with any questions about Green Tier or Green Tier audits at 920-648-4134