Category Archives: Management Systems

ISO 14001:2026 – An Opportunity for Change

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Introduction

ISO 14001 is the most popular environmental management system standard in the world. There are over 1.2 million facilities certified to this globally recognized standard. Many other organizations are using ISO 14001 as a model for their EMS but have not yet sought certification. The revision of ISO 14001 in April of 2026 offers an opportunity for organizations with an older legacy EMS to review and update to better manage risk.

The ISO 14001:2026 update made no material changes to the basic requirements of the standard. The revision did, however, clarify some important requirements, especially in Clause 6 on Planning. The restructuring of this section helps organizations improve processes for environmental risk management. The restructuring also helps certification bodies and other auditors better understand what ISO intends for this clause of the standard.

Clause 6 is important because it determines what the environmental management system is going to manage (environmental aspects). Results of planning help everyone using the EMS understand what environmental risks are important to the organization. Planning also helps users of the EMS understand what actions the organization is taking to control environmental aspects and impacts.

Better Understanding of Environmental Aspect and Risk

Environmental aspects cause risk or environmental impact. Reducing risk of environmental impact is the primary outcome that an ISO 14001 EMS should achieve. Clause 6 on planning has been ambiguous about the relationship between risk(s), opportunities, aspects, and impacts. This leaves it up to the organizations to interpret the requirements when planning the EMS.

This ambiguity has led to a wide variety of approaches to identifying environmental aspects and determining which are significant. Although these approaches technically meet the requirements of ISO 14001 they are marginally effective in controlling risk from aspects. The ISO 14001:2026 revision helps users gain a better understanding of environmental aspects, impacts, risks and opportunities.

ISO 14001 requires that organizations identify significant environmental aspects and to address risk and opportunity associated with these environmental aspects. However, the standard provides little guidance on why organizations need to identify some environmental aspects as significant. The standard is also unclear about what to do differently with significant aspects than with those that are not significant. This approach allows organizations flexibility to meet the requirement of this part of the ISO 14001 standard. However, this flexibility has led to a wide range of approaches to identifying significant environmental aspects, impacts, risks, and opportunities.

Clause 6 From an Auditors Perspective

Some conformant legacy EMS processes identify only a few environmental aspects and only 1 that is significant. Others are complex Failure Mode Effects Analysis (FMEA) type methods. Some with 7 or more factors used to calculate a Risk Priority Number (RPN). Often the FMEA has an arbitrary RPN cutoff value that limits the number of significant aspects.

Although these approaches met the basic requirements of ISO 14001, they often did not help organizations identify what was important. If the planning part of the EMS is weak the rest of the management system suffers. This is because the rest of the EMS relies heavily on the output of clause 6 planning.

ISO 14001:2026 revisions in clause 6 used a three bucket concept. The standard reordered the sequent of clauses to focuses on environmental aspects as a priority (Bucket-1). Bucket 2 are compliance obligations and Bucket 3 are risk and opportunities. See Figure 1.

Figure 1 – Three Bucket Concept

The following example of cheese making illustrates one approach to identify environmental aspects, impacts, determine which are significant. The case study describes how organizations can determine actions needed to address environmental risk and opportunities. It also provides information on how the ISO 14001:2026 EMS planning supports other parts of the EMS including auditing.

Process Flow Diagrams Aid Aspect Identification

Most organizations have systematic processes that add value and help organizations generate revenue. Often these processes have environmental aspects and impacts. Mapping the process flow is the first step in identifying environmental aspects. In manufacturing, businesses use inputs, like raw materials and energy in a sequence of processes that change these raw materials into something with more value that the organization can sell to customers.

Developing a process flow diagram of the manufacturing process is a critical step in aspect identification. Figure 2 is an example of a cheese making process flow diagram.   Raw milk is one of the inputs into the process. The cheese making process changes milk into cheese through a sequence of steps. The result of the process in cheese ready for sale to customers.

Figure 2 – Cheese Manufacturing – Whey Environmental Aspect

Waste whey is an output of the curdling and molding processes. If mismanaged it can have a significant water pollution environmental impact. To avoid fines and damage to the company’s brand risk of noncompliance from mismanagement of waste whey should be addressed by the company

The cheese making process has many other environmental aspects that may be significant like the use of cleaning chemicals and potential emissions of pollutants into the air. The first step in the Clause 6 planning process is to create an inventory of environmental aspects.

Use a process flow diagram like the one in figure 1 to identify environmental aspects.   Include someone with knowledge of environmental impacts are for the cheese making process. Once you have an inventory you can begin to evaluate them for importance using risk assessment techniques.

Deciding What Is Important

ISO 14001 requires organization’s determine what environmental aspects are important (significant) and thereby need to be addressed.

“The organization shall determine those aspects that have or can have a significant environmental impact (i.e. significant environmental aspects) by using established criteria.”

Risk assessment should be used to determine which environmental aspects are important and need to be controlled or improved. However, risk assessment can be subjective and imprecise. There are many approaches to performing risk assessment. The key is to not make it overly complicated. Keep it simple.

Figure 3 is an example of a simple risk matrix you can use to estimate relative risk based on likelihood and severity.

Figure 3 – 5×5 Risk Analysis Matrix – CorrectTrack.com

Across the top of the matrix are values for the likelihood that an aspect will have an impact on the environment.  The likelihood values in the top row increase from left to right, not likely (Value of 1) to Very likely with a (value of 5).  The Severity values along the left side of the matrix are similar with Low (1) at the bottom and Very High (5) at the top.

Use the matrix to estimate risk. Start by assuming that there are no existing controls to manage the risk of environmental impact even if you do have exiting controls in place. Pick a value along the Severity axis that you think is reasonable (1-5). Then pick a value along the Likelihood axis that you think is reasonable using the 1-5 scale. Multiply these 2 values together to give the estimated risk value. A group is often better at estimating these values than one individual alone. Also include an environmental professional with some risk assessment experience to guide the risk assessment process.

Significant Environmental Aspects

When making cheese, enzymes are added to the milk to help the milk coagulate into cheeses curds.  The enzymes come in returnable containers, and the likelihood is low and severity of an impact from adding enzyme is low. The risk score is calculated by multiplying the likelihood times the severity which gives a risk value of 1 which is low and represented by the color green on the matrix.

The generation of waste whey from the milk curdling process is highly likely (5) on the matrix because it happens every day that cheese is being made. The impact of improper disposal of waste whey is either high (4) or very high also (5). The combined estimated risk is calculated to be either 15 or 25 (high or very high) color red. This uncontrolled risk score helps in prioritizing environmental aspects for risk control   Figure 4 is an example of a prioritized aspect list.

Figure 4 – Prioritized Aspect List for Cheese Making

Good Planning Equals Good Audits

Skillful planning helps ensure good audits. Good audits provide critical information to leadership and others about the performance of the EMS and its ability to control risk to the organization. A well-planned EMS links environmental risk to the controls established to address the risk. This linkage is like a breadcrumb auditors can follow to check that the environmental risk is being addressed and the control is effective.

Breadcrumbs for Audits

A good example is Used Oil Management. Some of the equipment in the cheese factory is lubricated with petroleum oil. This oil needs to be changed by the maintenance department from time to time to protect the equipment moving parts from excessive wear. Without adequate controls used oil can be mismanaged and dumped on the ground, in sewers and storm drains causing significant environmental impact.

The likelihood and severity of environmental impact is high if used oil is mismanaged. Used oil is also regulated by government agencies and organizations and its leadership risk fines and even criminal penalties if waste oil is mismanaged.

To ensure that risk from the aspect of used oil is minimized organizations can establish several controls including Spill Prevention Control and Countermeasures Plans, secondary containment of used oil drums and tanks, and documented work instructions. By connecting the environmental aspect of used oil to these controls the auditor can quickly confirm what controls need to be in place and if those controls are effective. Audits would check that the SPCC Plan and the used oil work instructions are being followed.

Hierarchy of Control (HOC)

EMS Planning includes consideration of what actions can control environmental risk. Risk controls take several different forms, and not all are equally effective.  One method for determining the effectiveness of risk control is the Hierarchy of Controls (HOC).  HOC is based on the concept that some types of control are more effective at reducing risk than others. In the HOC “Elimination” is one of the methods to control risk.

If a cheese factory is able to eliminate the process that generates the whey waste the risk of that aspect is also eliminated and the risk score goes from 25 to 0. Figure 5 is a version of the HOC used to calculate the effectiveness of a particular type of operational control Engineering controls reduce risk by 60% and administrative controls by 40% and so on.

Figure 5 – Hierarchy of Risk Control – CorrectTrack

Layers of Protection (LOP)

Another important concept of risk control is Layers of Protection. If we apply several different controls to the aspect of Waste Whey we can reduce risk from this aspect significantly.The calculated uncontrolled risk score for waste whey at 25 (Very High). We can use an engineering control (treat the wastewater before discharge). This will reduce that risk score by 60% down from 20 to 8 (20 x .4=8). This reduced value is the residual or remaining risk before any additional control.

A risk value of 8 for the aspect is still high (orange). Another layer of protection is desirable to reduce the risk further. The organization needs to be maintain the wastewater treatment process. Leadership should confirm that treatment plant operators are competent to ensure the treatment is done properly. Training and competence are a form of administrative operational control in the Hierarchy of Control (See Figure 3).

Appetite for Risk

This additional layer of protection reduces the risidual risk to 4.8. Depending on the organization’s appetites for risk, this value may be low enough. Leadership should review and confirm risk to the organization is managed adequately. Repeating this process for all other environmental aspects ensures that risk is assessed and addressed to an acceptable level.

Tying It Altogether

The ISO 14001:2026 revision emphasized the importance of clause 6 and good planning. The intent is to encourage organizations to review their planning process. Organizations with a legacy EMS will benefit from reviewing the planning parts of their EMS. Important questions to ask during this review are:

  • Was a process flow diagram or something similar consulted during the aspect identification process?
  • Are risk assessment processes used based on likelihood and severity of impact?
  • Were aspects with higher risk values prioritized for action?
  • Does the risk assessment process consider the hierarchy of controls when deciding if risk had been adequately addressed?
  • Has linkage between the environmental aspects and the actions taken to control risk been documented?

Answering yes means the planning part meets the requirements of ISO 14001:2026 and is addressing environmental risk. If not maybe now is a good time to make some changes to the planning process.

About the Author:

Kevin Lehner is a senior member of the ANSI US technical Advisory Groups for ISO 14001, 45001 and ANSI Z10.  He is leading the international group establishing a new guidance standard in the ISO 14002 series on using ISO 14001 to address environmental topic areas.  He is a certified ISO management systems lead auditor performing frequent ISO audits for ECSI audit clients.  He also is a frequent instructor for ISO 14001, 9001 and 45001, auditor and lead auditor Exemplar Global certified courses.

ISO 45001 Clause 6 Revision – Streamlining Proposal

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ISO committee TC 283 has begun a Systematic Review of ISO 45001 that is expected to be completed in early 2027. Clause 6 on Planning is one of the key areas of focus for the committee. Once the systematic review is complete a revision will be finalized and the current version of the standard (ISO 45001:2018) will be repealed.

The revision process offers the opportunity to incorporate changes to the ISO High Level Structure (HLS). It also provides an opportunity to review areas of the standard that have caused confusion for users since it was first published in 2018. One of these areas is Clause 6, the planning part of the management system standard. This section is currently over 1100 words and three pages long. User have complained about confusing terms including risk, opportunity, OHS hazard OHS risk, other risks and other opportunities.

ISO 45001 systematic review

Simplify and Clarify Clause 6

For some users, these confusing terms make it difficult to comprehend what the standard is supposed to be managing. It also duplicates of requirements in other parts of the ISO 45001 standard. One proposal to simplify and clarify clause 6 would reduce the number of words from 1100 to a little over 300. Comments from other committee members of this proposal rang from “this is great, all standards should be this concise” to “this goes way too far and should not be considered”.

Make a Fresh Start

The concept is to begin the review clause 6 revision process with an almost clean sheet of paper and build on the text from there. If committee members believe that additional text is needed they should justly the addition including:

  • Why the addition is needed in the requirement part of the standard and not as guidance in the annex part of the standard
  • A description of what evidence auditors should look for a conformance to the requirement
  • It does not duplicate another requirement somewhere else in the standard.

If the additional desired text is more guidance than requirement it should be placed in the annex of the standard, not in the requirements part or perhaps, in an entirely different document like ISO 45002.

Reduce Confusing Terms

The streamlining proposal also clarifies what ISO 45001 is supposed to be managing by eliminating some confusing terms in clause 6. Terms like “Risk and Opportunity, “other risk” and “other opportunity” and replacing them with the term “OHS Hazard Risk”. This proposal for streamlining and simplifying clause 6 is already controversial with some members. It is likely to be hotly debated over the next few months as the ISO 45001 revision process gathers momentum in committee meetings later this fall..

Big 3 Standards Now Under Revision – What You Need to Know

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The 3 big ISO standards are now under revision. ISO 14001, 45001 and 9001 are being reviewed and revised simultaneously.  Recently, ECSI attended meetings of the US Technical Advisory Groups (TAG) for both ISO 14001, and 9001 in Washington DC where the upcoming revisions were discussed. We have also been participating in the US TAG to ISO 45001 and in meetings discussing revisions to that standard.

The revised standards will be released in a few years when organizations will be need to conform with the revisions. The following is a brief discussion of what to expect for revisions to each standard.

ISO 14001

ISO 14001 was first published in 1996.  Since then, it has been revised twice. Once in 2004 and again in 2015.  The 2015 revision incorporated a major change. This change involved converting the entire standard to the ISO High Level Structure (HLS).  Although the revision will not introduce new requirements, it may make changes to clarify some of the key requirements such as the relationship between risk and opportunity and significant environmental aspects.

The revision will integrate changes to the HLS and address concerns raised by users of the standard over the past 9 years.   Initially the ISO 14001 revision committee considered issuing an amendment with the few HLS changes.  The committee thought that this would be easier and take less time than a full revision.  The committee was also concerned about opening the standard up to a broader revision that could result in additional requirements.

Recently however, the committee discovered that the amendment option has significant drawbacks making it an unlikely choice.  The amendment route would have resulted in issuance of a separate 28 plus page document to be used with the current 2015 version of the standard.  Users would have to reference 2 different documents when using the new amended standard.  The committee is looking at other amendment options, but it appears the only way to avoid the 2 document problem is to do a full revision and then issue a single revision document.

If a full revision does occur, it provides more opportunity to address sections of the standard that have caused confusion for users.  Additionally, it creates an opportunity to take advantage of changes in the HLS that offer flexibility when using the term “risk and opportunity” in the planning section of the standard.

ISO 45001

The committee revising ISO 45001 has decided to do a full revision instead of just a limited amendment.  This option avoids the 2 document problem created by the amendment route and gives the committee greater flexibility in what can be changed. This includes clarifying and streamlining parts of the standard that users have found confusing and redundant.

Clause 6 (Planning) is one of the parts that has potential for improvement to make it more user friendly for small and medium sized organizations.  Clause 6 of the standard in the current version was over 1100 words and three pages in length.  One proposal being circulated for the revision by the committee would dramatically reduce the text by two thirds to only 318 words and 1 page.

There is also a proposal to refer to “OHS Hazard Risk” when describing what the OHSMS is supposed to be managing. It is thought that this may help reduce misuse of the terms “Risk” and “Hazard” interchangeably.

ISO 9001

The ISO 9001 committee has also chosen the full revision route.  However, the committee is taking a more aggressive posture when deviating from the HLS.  For over a decade ISO headquarters has insisted that it will not allow deviations from the HLS text for any of the standards.  The ISO 9001 revision committee wants to exclude certain new requirements introduced by the updated HLS.

The committee believes the new HLS requirement about climate change is not applicable to a quality management system. Although the committee believes that climate change consideration is important, they believe including it as a requirement in 9001 is inappropriate.

Conclusion

The revision of the three big ISO standards is not expected to result in new significant or reorganization of the standards.  The revisions are more likely to improve the standards by reducing unnecessary text and eliminating redundant requirements.  Organizations who meet the requirements of the current ISO standards should not need to make big changes to their Environmental, Occupational Health and Safety (OHS) and Quality management systems.  The revisions will also make these standards more accessible to small and medium sized businesses around the globe.

OHS Hazards and OHS Risk

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The terms OHS Hazards and OHS Risk have been in use for decades.  But these terms are often misused by OHS professionals by casually interchanging them. This creates confusion about what an OHS management system is supposed  to manage because there is a significant difference between an OHS Hazard and OHS Risk.

ISO 45001 defines the term “hazard” as a “source with a potential to cause injury and ill health”.

The standard also defines OHS risk as a “combination of the likelihood of occurrence of a work-related hazardous event(s) or exposure(s) and the severity of injury and ill health  that can be caused by the event(s) or exposure(s)”.  Using the terms hazard and risk interchangeably is a mistake. It is also confusing because a hazard is something that has the potential for harm. Risk is a measure of the likelihood and severity of harm from a hazard.

OHS hazards are identified using terms like burn, laceration, crush, struck by, over exposure, psychological harm and many others.  To make sense in an OHS management system context, risk should be expressed as a value like high, medium or low risk. 

In an OHS management system we identify hazards (hazard identification). We then assess the likelihood and severity of harm that could result from the hazard (risk assessment).  

The term OHS Hazard Risk might be a better way to describe what ISO 45001 is supposed to manage. It may help stem the misuse of the terms hazard and risk in OHS management.  The term OHS Hazard Risk also conveys the notion that OHS hazards are the source of risk. Additionally, it helps users of standards like ISO 45001 understand that OHS management is about addressing the risk (likelihood & severity) of harm.  In an OHS management system we manage the  risk not the hazard.  Risk is managed by implementing controls to reduce the likelihood and/or the severity of the harm.

URGENT ALERT – ISO Climate Change Amendments!

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ISO recently amended all ISO management system standards (MSS) to include requirements for organizations to consider the effects of climate change. If your organization holds a current certification to ISO 9001, 14001 or 45001 you can expect to be asked “has your organization determined whether climate change is a relevant issue?” during your next certification audit.

This new requirement is the result of a change to the ISO Harmonized Structure (Appendix 2 of the Annex SL in the ISO/IEC Directives Part 1 Consolidated ISO Supplement). Here is more background on the Harmonized Structure also referred to as the High Level Structure and Annex SL.

ISO announced the new requirement in an IAF/ISO Joint Communique indicating the climate change text highlighted below is effective immediately for all MSS.

ISO HLS revised requirements for context determination

Most organizations certified to ISO 14001 should be able to answer auditors questions about climate change relevance. Other organizations with current certification to ISO 9001 and/or 45001 might find it more difficult to avoid a nonconformity to these new requirements if they don’t act soon. Each organizations context is different and will influence how they address climate change in their MSS

Contact us if you have questions about how these new requirements might effect your organization ISO certification status.

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.