Category Archives: Management Systems

Pro Tips for Best EHS Audits (Part 3): EHS Audit Follow-up

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The purpose of an EHS audit follow-up is to check that EHS risk, including risk of noncompliance, is managed to a level that the organization considers acceptable. Noncompliance with applicable government laws and other requirements are examples of EHS risk sources that need to be controlled. An EHS audit checks that risk controls are in place and effective.  Risk controls can be engineering controls like air pollution control devices, administrative controls like training and work instructions and others.

EHS Audit Findings

The results of an audit are called findings. These can either be positive findings that the controls are in place and effective, or negative. Negative findings are nonconformance’s. Positive findings are good news but not something the organization needs to act on. Positive findings confirm that “what should be is” and that “what should not be is not.

Negative findings however are actionable and create opportunities to improve EHS performance. In Part 2 of this EHS Compliance Audit series, we discussed how negative findings are written and communicated verbally at the end of the audit. As a follow-up to the active evidence gathering and verbal reporting, a written report should be prepared and distributed to document the results of the audit.

Preparing the EHS Audit Follow-Up Report

The audit report presents the results to the auditee and others and helps an organization gauge EHS performance. The report should be concise and to the point and the tone of the report should be factual and nonjudgmental.   

A key part of the EHS audit follow-up report are the negative findings that were made during the audit. The EHS audit follow-up report formalizes the findings in a way that the auditee can act on them. The reported negative findings need to include enough information so that they can be investigated and ultimately fixed in a way that they do not happen again.

Here is an example outline for an EHS audit follow-up report.

  • Executive Summary
  • Background Purpose and Scope
  • Findings
  • Conclusions
  • Recommendations
  • Discussion
  • Appendices

Correction and Corrective Action

Negative EHS audit findings point to EHS risks that need to be better controlled. They are the result of a potential noncompliance with a legal requirement or discovery of some other issue. If left uncorrected they can increase risk and lead to enhanced legal action by a regulatory agency (knowing and willful violation). To avoid exposure to these enhanced penalties, it is important that organizations have a good corrective action process in place.

There are 5 steps in an effective corrective action processes.

  1. Short Term Correction
  2. Investigate the Cause
  3. Identify a Corrective Action
  4. Implement the Corrective Action
  5. Verify the Corrective Action is Effective

The following is a brief description of these steps.

Short Term Correction

Findings that identify a potential serious risk need to be addressed as soon as possible. Continuing to operate equipment that exposes workers to injury after a finding is made is bad business. If a worker were to become injured after the nonconformance was reported the penalties and fines could escalate dramatically.  A correction to quickly reduce the risk from the nonconformance needs to be put in place as soon as practical.

Investigate THE Cause

Once the correction has been put in place a corrective action plan needs to be established. Responsibility to investigate the cause of an audit finding should be assigned to someone with knowledge of and experience with the corrective action process. This knowledge and experience will help identify the root cause of the finding. Once the root cause is established an appropriate corrective action can be proposed that prevents the problem from recurring in the future.

Knowledge and use of root cause analysis tools like “5 Why Cause Analysis” ensure the cause of the unacceptable risk level is identified. Here is an example a “5 Why Cause Analysis”.

This example is for an incident that happened at a roll calendar for polishing extruded plastics sheets. An employee was caught in an in running nip between the rolls and luckily only sustained a recordable injury. This incident could have easily been an amputation or a fatality.

roll calendar for polishing extruded plastics sheets
Why?Answer
Why was the OHS hazard of being caught in the nip on the calendar not addressed?The machine was new, and no one thought to do a Job Safety Analysis (JSA) before it was installed and operated.
Why did no one perform a JSA?Performing a JSA to review potential OHS hazards and risk are not part of the capital investment approval process.
Why was OHS hazard and risk review not part of the capital investment process?The manager of the extrusion department manager did not know that a JSA hazard and risk review should be undertaken for all new equipment as part of the purchase process.
Why was extrusion department manager unaware of the need to review hazards and risks for new equipment?An existing employee had recently been promoted to manager of the extrusion department and they had not been informed of the requirement.
Why had the new extrusion department manager not been informed?Our organization has not established a process to identify training needs and provide training to employees when they transfer to a new position within the company.
Table 1 – Example 5 why analysis

Identify a Corrective Action

Once the cause is established, a suitable corrective action can be identified to reduce the risk to an acceptable level. The effort needed to identify a suitable corrective action is proportional to the finding risk level. The higher the risk, the more effort needed to figure out the best way to address it. A finding that an emergency evacuation map could be hidden behind a door when it is opened, is much easier to correct than the finding of an ineffective control to treat wastewater discharge to a municipal sanitary sewer.  

The cause analysis process should have an approval step to confirm the cause analysis was performed with skill and that the corrective action is aligned with the identified cause of the finding. This review and approval can be done by the auditor who made the finding or others in the organization who can impartially review the cause and proposed corrective action.

If the cause and/or the proposed corrective action are found to be deficient during the review, the assignees should be consulted and asked to rethink the cause analysis and corrective action. The evaluation and approval of potential corrective actions requires striking a balance between risk and opportunity. It is not possible to reduce all risk levels to zero.

Some processes have hazards with risk that are difficult to control and the organization needs to think carefully about what level of risk it is willing to accept. In running nips on plastic extrusion rollers is a good example. It is very difficult to properly guard an in running nip on these machines. The guard would prevent the process from working properly.

As a result, the corrective action cannot be the elimination of the hazard or installation of a physical guard (engineering control).  Instead, there may need to be several independent controls such as installing a rope e-stop, providing training to employees on how to operate the process safely and even evaluating the operators competence to ensure they understand the hazard and the associated risk. 

Once both the cause and the corrective action(s) are approved the assignee should be authorized to implement the corrective action.

Implement the Corrective Action

The implementation of the chosen corrective action may take days, weeks or even months depending on what needs to be done. Moving an emergency evacuation sign to a better location can be done almost immediately while designing and installing an upgraded wastewater treatment process may take many months.

Verify the Corrective Action is Effective

Verification that the corrective action has been implemented and that it is effective is the last step in the process. It confirms that the problem causing risk, has reduced that risk. The verification can be done upon completion of the corrective action or during the next audit. When the corrective action is verified, it can be closed.

Tracking EHS Audit Corrective Action Progress

Historically, keeping track of progress toward completing corrective action was done with paper forms that went from in-basket to in-basket. Once complete they were placed in a file drawer for storage. Later, electronic methods including excel spreadsheets and other types of electronic documents were used with some success. However, these tracking methods require much effort and often lead to miscommunications or missed deadlines of incomplete corrective actions for findings. The result was the corrective action process was not successful in reducing risk in a timely fashion and increased risk to the organization. 

Within the last few years cloud-based applications have emerged that solved many of the problems with paper or spreadsheet corrective action tracking systems. These applications allow quick access to users and are readily accessible almost anywhere.

Modern corrective action application
Figure 1 – Modern Corrective Action Application

Cloud based database applications help organizations quickly find the status of any CA and drill down to details for each CA.

Figure 2 – Drill Down Corrective Actions Detail

Applications like CorrectTrack establish users permissions to view, change, verify and approve corrective actions. A permissions based peer review process also helps ensure that corrective actions are investigated thoroughly and verified before they are closed.

Other advantages of a cloud based app like CorrectTrack are:

  • Notify persons of status changes of a CA
  • Define a standard process for doing CA
  • At a glance dashboards for users
  • Provide notifications when CAs are coming due, or past due
  • Provide a record of who changed what, when and why
  • User permissions allow visibility of the CA system to leadership

Conclusion

Effective corrective action processes are powerful tools that help organizations improve EHS performance over time. Investing in, and continually improving the corrective action process will provide a significant short term and long term return.

This EHS Audit Follow-up post is part 3 of a three part article on EHS Auditing. Part 1 and 2 discussed how to plan an EHS audit and conduct an EHS audit. This concludes our three-part series on EHS audits.

We welcome and encourage feedback on this series. Contact us directly at kalehner@envcompsys.com and 262-949-2965, or visit us online for more information: ECSI or CorrectTrack.

RDO Equipment Co. Achieves ISO 45001 Certification

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RDO Equipment Co. Founded in 1968, RDO Equipment Co. sells and supports agriculture, construction, environmental, irrigation, positioning, and surveying equipment from leading manufacturers, including John Deere, Vermeer, and Topcon. RDO Equipment Co. is a total solutions provider with more than 75 locations across the United States and partnerships in Africa, Australia, Mexico and Ukraine. RDO contacted ECSI for assistance in developing an Occupational Health and Safety Management System to help improve its OHS performance.

RDO also wanted to show its business partners, customers and employees, their commitment to keeping employees safe. RDO chose to align the OHS management system with ISO 45001. They also decided to initially seek certification from an accredited certification body for their corporate headquarters and one of the company stores. Their intention is to certify the remaining 42 stores over the year or so. ECSI conducted an initial gap assessment that helped RDO identify gaps that needed to be filled before getting certified.

Gaps were entered into a database application tool (CorrectTrack) and assigned to the OHSMS implementation team for follow-up. One of the gaps identified was the need for a comprehensive Job Hazard/Job Safety analysis. ECSI helped develop process maps that supported JHA/JSA development at one of the RDO maintenance facilities. Below is an example of how the results of the JHA/JSA risk analysis were recorded.

This tool helped RDO evaluate the effectiveness of existing risk controls and identify priority hazards for additional risk reduction. The tool also helped internal auditors identify what material risks need to be audited during the internal audit process.

ECSI also helped RDO train its internal auditors in performing audits to the ISO 45001 standard. This was done in a three day combined internal audit training and actual audit at the corporate headquarters and one of the RDO maintenance facilities. ECSI assisted RDO in preparing for several management review meetings that were conducted prior to the Stage 1 and Stage 2 audits by an accredited certification body. Congratulations RDO on a successful outcome to the ISO 45001 implementation and certification process.

ISO 45001 Webinar – FREE!

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Watch Webinar

ISO 45001 is an international standard that helps organizations improve Occupational Health and Safety (OHS) performance.  The ISO 45001 standard can be used to ensure workers are safe by protecting them from workplace injury and ill health.  As the Vice Chair of the US Technical Advisory Group to ISO 45001, I have been seeing a significant rise in awareness of ISO 45001 benefits.  Environmental Compliance Systems, Inc has also helped many organizations plan, implement and integrate an ISO 45001 OHSMS with their other business management systems.   A recent webinar produced with ASSP describes the many benefits of an ISO 45001 OHSMS.  Here is a link to free ASSP webinar: https://player.vimeo.com/video/844292169?. Please watch if you are interested in improving your organizations OHS performance.

Leadership Commitment and Management Review

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Picture of Leaders

Leadership commitment to a management system is critical to its performance. Encouraging support is sometimes challenging. The management review process required by ISO management system standards can help gain leadership commitment.

Do’s and Don’ts

Coordinate management review with management other business review meetings. Conducting “management review” during regular business review meetings gives the sense that the management systems is part of the overall business. Management reviews conducted infrequently and apart from the other important business management meetings leads to a silo-ed perception of the management system.

Make management review value added. Ensure the information being presents is actionable by leadership. Give them a few choices for recommendations with supporting information and ask them to decide. They will appreciate your opinion and recommendations to help make decisions.

Do the Math and Have Backup.

Defend your recommendations for improvement with cost and return on investment information. Showing leadership how the management system helps save and even makes money, contributes to their support and commitment.

Take Good Notes

Recording leadership decisions during the management review helps ensures follow-up. Records of management review are also evidence of their leadership commitment, especially during audits.

Timely Management Review Follow-up

Follow-up on management review recommendations in a timely fashion and report on progress at the next management review opportunity. This will enhance leaderships perception of the management system, their support and commitment.

Management Review Frequency

Most organizations perform periodic reviews of the business performance to make sure things are going along smoothly and to make any course corrections needed. Integrating the ISO system management review with these regular business review meetings will help ensure that:

  • Management system performance issues are addressed in a timely fashion
  • The management system is integrated with all other business processes
  • Timely information is provided to leadership to help make important business decisions

Management Review Inputs

Management review meetings should not necessarily address all management review inputs during each meeting. Management review inputs that should be reviewed at every management review include:

  • Follow-up from previous management reviews
  • Status of actions from previous management reviews;
  • Status of corrective actions and incident investigation
  • Progress toward achieving objectives.

Management review inputs to be reviewed less frequently and as needed such as

  • Customer Complaints and interested party concerns
  • Changes including new compliance obligations
  • Adequacy of resources
  • changes in risks and how they are being addressed
  • Audit results

Management Review Outputs

The purpose of management review is to ensure the management system is able to achieve it intended outcomes. The outputs of management review are an important part of the Act part of the Plan-Do-Check-Act continual improvement cycle. It is where leadership has the opportunity to review the information generated in the “Check part of the PDCA cycle and intervene (Act) and continually improve the management system

Records of management review are the notes of the meeting (output notes). They are required by all ISO management system standards. Outputs are what leaderships asks the organization to do to improve performance. These records are also excellent evidence of leadership commitment during third party audits.

Conclusion

The goal of management review is to provide information to leadership that it can act on. Planning and conducting good management reviews will enhance leaderships opinion and support of the management system.

ISO High Level Structure Revision

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The ISO High-Level Structure (HLS) is the basis for all management system standards and is now being revised by ISO.  These changes will affect all management system standards.  Users of ISO management system standards such as ISO 14001, 9001 and 45001 will need to evaluate how these changes will affect the organizations ISO management systems.

Introduced in 2012, the HLS was created to help better integrate quality, environmental and health and safety management systems.  Prior to its introduction ISO 9001 had a different structure that ISO 14001 that complicated integration of the management core processes such as corrective action and management review.  The HLS solved that problem.  The revision introduced a new name for the HLS and it is now called Annex L, Appendix 2.

The revision will also introduce guidance on use of the HLS for standard writers and users.  This guidance is called Annex L, Appendix 3.  Both Annex L, Appendix 2 and 3 will be combined as a table.

Proposed Structure of Annex L Appendix 2&3

Appendix 2 is in the final stages of an initial “limited” revision and not yet available to the public.  Appendix 3 is in mid-stage revision and should be approaching the final stage later this year.

Here are a few of the most important changes to Annex L, Appendix 2 from the “limited” revision:

Definition of Risk

A lengthy debate is ongoing within ISO about if a revision to the definition of “Risk” is needed. “Risk” is currently defined in the HLS as “the effect of uncertainty”. Some within ISO argue that a better definition is “the effect of uncertainty on objectives“.

Others fear that the addition of the words “on objectives” to the definition of risk will cause confusion in standards like ISO 9001, 14001 and 45001. They believe this because these standard have a specific requirement to create measurable “objectives” within the management system.

The debate over the definition of risk has lead to several proposals including eliminating the definition of risk entirely from the HLS. A subgroup has been assigned the task of sorting this difficult issue and the results will be reflected in a future revision of the HLS. For now however the definition of “risk” will remain as it is in the HLS.

Expected Outcomes Vs Results

The previous version of the HLS used the term “expected outcomes” to describe the results organizations should expect from its ISO management system.  Some users found the term “expected outcomes” confusing so it has been changed to “expected results”.  The change was also made to simplify translation to other languages.

Outsourced Processes

The old HLS used the term “outsourced processes”.  Manufacturers sometimes send their products to other organizations who perform specialized processes like heat treating or electroplating. This relationship between organizations was called “outsourcing” in the previous version of the HLS. The concept of “outsourced processes”  however does not apply as well to other disciplines such as environmental management or health and safety management systems.

The term “external provider” is now being used in place of outsourced process.   This change has been made in response to several comments that found the term “outsource” unclear.  The use of external provider clarifies that outsourced, contracted, and purchased products, services and processes all need to be controlled by the management system.

Documented Information

The use of the terms “maintain” and “retain” to describe what needs to be done with certain types of documents in the management system has been replaced with the term “shall be available”.  This change has been made to avoid confusion between maintaining and retaining documented information. This change is not expected to impact organizations with mature document control process and management systems.

Internal Audits

This part of the HLS has been substantially reorganized. The title of 9.2.1 was changed to General and 9.2.2 Internal Audit Program has been added.  This change has been made for ease in understanding. Now the two distinct concepts covered in the paragraph (what an audit program entails and what should be considered when establishing an audit program) are listed separately.

Effects of the Annex L, Appendix 2 and 3 Revisions (Whats Next?)

The revision of Annex L is not expected to have a significant immediate effect on ISO standards or ISO management system audits. The revisions will not requires revision of any of the ISO management system standards until these standard are revised and updated as required by ISO. However, organizations in the process of implementing an ISO management system or integrating a new discipline specific standard such as ISO 45001 into an existing management system structure, should anticipate that these changes will appear in future revisions of ISO management system standards.

Results of ISO 45001 US TAG Meets in Dallas, TX  – February 22-26, 2016

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We recently participated on the leadership team for the United States Technical Advisory Group (US TAG) for the Development of the  new ISO 45001 standard for Occupational Health and Safety management systems.  Group Photo at ISN

The purpose of the week long meeting held at the ISN headquarters in Dallas, TX was to disposition over 800 comments on ISO/DIS 45001.  The US TAG successfully dispositioned all of the major issues and many of the individual comments.  Our role at this meeting was as co-chair of a subcommittee with Vic Toy for Clause 6 – Planning.  Our section had 157 comments to review and decide how they would be addressed.

The meeting was attended by about 70 participants representing business, organized labor and government.  Major issues addressed during the meeting included questions and comments like:

  • Should organizations be required to use the hierarchy of controls when reducing risk?
  • Does redundancy add clarity or confusion (frequent references to workers and worker representatives)?
  • Should organizations be required to assess risk to the management system (other risks) or is this already addressed by the clauses of the standard?
  • When must workers be asked for an opinion (consultation) and when must workers have authority to influence decisions made by management about risk control and other management system issues (participation)?

We have posted some articles about the following on our website blog if you are interested in learning more about these important issues.

  • ISO 45001 – Hierarchy of Controls
  • ISO 45001 – Other Risks and Other Opportunities

The public comment period in the USA is now open until April 1, 2016 so if you are in the USA and your organization would like to submit comments for consideration send me an email to tagosh@envcompsys.com and I can help you get the comments to the right place. Also please feel free to call or email with any questions about ISO/DIS 45001.

ISO High Level Structure and EH&S Management Systems

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ISO 14001 and OHSAS 18001 are undergoing significant change intended to improve these standards.  The new ISO High Level Structure will align all ISO standards along a common management systems structure and promote integration.   The recent US Technical Advisory Group meeting in Orlando, Florida was a particularly enlightening conference for us where US TAG members were able to share their ideas of the way the HLS applies to EHS management Systems.

ISO HLS & EHSMS

ISO HLS & EHSMS

An important part of the revision processes is being able to communicate to current and new users how the standards are changing and how these changes will affect an existing EHSMS.  This diagram represents how we at ECSI see the developing changes to ISO 14001 and ISO 45001 and the relationships between some of the important clauses of the revised standards.

We are interested in understanding how users of the EHSMS standards feel about the changes and what information they need to begin to plan for the changes to their EHSMS.  ECSI will be conducting a short, one hour webinar Tuesday, April 22, 2014 from 10am-11am Central Standard Time.  The purpose of the seminar is to provide the current state of the revision process and to discuss how we see the EHSMS standard revisions progressing.  If you are interested in participating in one of these webinars send us an email to webinar@envcompsys.com and we will reply with the logon instructions.

Revision to ISO 14001:2004 – Defining Significant Environmental Aspects/Impacts – Sense and Semantics

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Over the last two decades practicing as an ISO 14001 auditor, consultant, and teacher, I have found that many individuals and organizations misunderstand the intent and meaning of the terms “significant environmental aspect” and “significant environmental impact.”  With the revision to ISO 14001:2004 well under way, perhaps now is a good time to attempt introducing language or definitions into ISO 14001:201x that will help individuals and organizations better understand the term “significant”, and the distinction between the terms “aspect,” and “impact.”   Such clarity would enable individuals and organizations to better interpret  what exactly must be done according to the standard. This confusion in meaning is understandable because, at least in the English language, there are several definitions or “senses” or “subsenses (meanings in specific contexts) of the term “significant.”  The senses or subsenses that are applicable within the context of ISO 14001 can be found in the MerriamWebster Collegiate Dictionary (Tenth Addition) as follows:

2   a: having or likely to have influence or effect:  IMPORTANT  <a significant piece of legislation>;    also: of a noticeably or measurably large amount <a significant number of layoffs> <producing significant profits>

In order to fully comprehend this definition, you need to refer to the Explanatory Chart and Explanatory Notes at the beginning of the dictionary, which describe the meaning of the numbers (2), something called a “sense number”; the small letters (a), which are “sense letters”; the colon (:), which is used to separate two or more definitions of a single sense; and the italicized word “also,” which is called a “sense divider” and is used to introduce a meaning that is closely related to but may be considered less important than the preceding sense.  If a capitalized word is used to define a sense of the word, that capitalized word, in this case IMPORTANT, is defined as a synonym of the term being defined.

The sense number 2 definition of the term “significant” has several subsenses with different meanings.  One of these subsenses means “important.”  The other means “a noticeably or measurably large amount.”   What has happened over the years with the interpretation of ISO 14001 is that many individuals and organizations have applied only the second subsense of the term – “a noticeably or measurably large amount,” – when they are determining which environmental aspects they consider significant.  They ignore the other, and arguably more important, subsense of the term –  “IMPORTANT.”

The effect on an organization’s Environmental Management System of only considering the part of the definition of “significant” that means “a noticeably or measurably large amount“ has been that an organization typically excludes from its list of significant environmental aspects those that are “important” to them for  reasons other than their being “a noticeably or measurably large amount”. This typically includes environmental aspects for which the organization has established operational controls (work instructions) to ensure that the environmental impact of the significant environmental aspect is controlled to the level desired by the organization.  

An example might be waste light bulbs, batteries, and other electronic waste.  Although most organizations have procedures for ensuring that these wastes are properly recycled (work instructions or procedures), many do not identify these wastes as significant environmental aspects because they believe the presence of the operational control has reduced the potential impact from these wastes to a point where they do not constitute a  “noticeably large amount.”   They do not apply the other subsense of the word “significant” with the meaning “important.”  Proper management of waste light bulbs is obviously important to the organizations because they have established a procedure (operational control) for ensuring that they are managed in a certain way. 

The unfortunate consequence of not including waste light bulbs as a significant environmental aspect is that this important environmental aspect  then becomes transparent to the management system.  The organization’s performance toward ensuring that waste light bulbs are managed correctly is not routinely measured or audited during internal or other system audits. 

To correct this problem the US TAG should consider adding the following definitions to ISO 14001:201x:

3.xx significant environmental aspect The cause of a significant environmental impact

3.xx significant environmental impact The potential or actual environmental effect or risk caused by a significant environmental aspect that an organization intends to manage or is managing through operational controls and/or environmental objectives, targets, and programs

The definition of significant environmental impact above includes reference to “risk,” which is meant to address the risk to the organization, including potential regulatory noncompliance.  The result of including the word “risk” in the definition is that organizations controlling  an environmental aspect to manage a potential risk of noncompliance will need to identify that environmental aspect as “significant.” Close attention should also be paid to the way in which the terms “significant environmental aspect” and “significant environmental impact” are used in the standard to avoid confusion between these terms.  The use of the term significant environmental impact” should be limited compared to the use of the term significant environmental aspect.  The term significant environmental impact should be used only in the section of ISO 14001:201x addressing identification of environmental aspects.

Kevin A. Lehner, EMS-LA, CHMM – January 11, 2013

A True Story – Why ISO 14001 Works

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Background

It has been over seven years since we first began helping a medium sized automotive equipment manufacturer in the midwest implement a company wide ISO 14001 EMS. They were getting pressure from their customers to prove they were good environmental performers and an ISO 14001 certificate was the best solution. We helped them with environmental aspects, setting up the EMS and identifying regulatory compliance requirements. As we were completing the project we performed a round of internal audits to check that each facility was complying with the applicable  legal requirements.

The Audit Finding

One of the findings of our compliance audit was that at one location, the company was operating unpermitted production painting equipment. The audit team could find no records of correspondence with the State permitting authority about this new equipment. It had been commissioned sometime after an initial Title V permit application had been prepared for the facility. The paint operation was an important part of the manufacturing process and it was not possible to simply shut the process down. Doing so would have resulted in delayed shipment of product and dissatisfied customers.

The Response

Although the discovery of this potential noncompliance was uncomfortable news for the organization, at least they now had a better picture of the potential risks they were facing. They examined the process closely and decided that it was time to upgrade. They worked it out with the state permitting authority to replace the old system with a new more efficient paint system.

Fast Forward

Over the last several years we have continued to perform periodic EH&S compliance, ISO 14001, and OHSAS 18001 internal audits to support their continued certification to these standards.. During a recent compliance audit at one of the facilities we were delighted to see a new process being installed. It means the company continues to grow but, from an auditors perspective, the stack ducting through the roof becomes a great opportunity to check the EMS effectiveness to control noncompliance risk. As we walked by the new process I could see the auditee cracking a half smile as I asked a few questions about the new equipment and construction underway. He knew where this audit was going.

The audit was actually a combined one-day environmental and OSHA compliance audit so we had a lot of ground to cover in 8 hours. When the audit schedule called for review of compliance with state air emission permits, I asked what they knew about the potential emission from the new process. The audtee said “the process had the potential to emit a hazardous air pollutant at levels requiring permitting before installation of the equipment”.  The auditee then produced the construction permit they had been issued by the state?  The EMS had worked to help the organization identify the need to obtain a permit, well in advance of beginning construction on the new process.

Results Matter

Discovery of unpermitted emission sources during internal and compliance audits is not uncommon for us even today. Helping organizations identify and manage risks of noncompliance in the short term provides some satisfaction in our work. But having the opportunity to see the results of an effective EMS that we helped implement and, how that EMS has helped manage risks long term, is particularly gratifying.

Skepticism of the benefits of ISO 14001 will continue to linger especially with the uniformed. However, organizations interested in managing environmental risk and becoming more sustainable need to understand how the audit processes, embedded in ISO 14001, can be used to support an organizations sustainability efforts, promote successful outcomes and provide confidence by other stakeholder that environmentally, things are as they should be.