A True Story – Why ISO 14001 Works

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.

Integrated EHSMS

Integration of Environmental Management Systems, (EMS) and Occupational Health and Safety Management Systems (OHSMS) into an EHSMS (Environmental Health and Safety Management System) is the way to go. ISO 14001:2004, OHSAS 2007 are your best choices for models of continual improvement management systems that are easily integrated. Both of these standards share many common elements and integration avoided the confusion of having separate process that address these in the EMS and OHSMS.

Separating the results of environmental aspect identification required by ISO 14001 and the hazard identification and risk assessment required by OHSAS 18001 alos helps avoid confusion. Get some help from an experienced, competent professional when you are deciding how to identify aspects and evaluate hazards and risks. If this part of the EHSMS implementation process is not done with skill, the effectiveness of the EHSMS will be greatly compromised.

Here is a link to a brief discussion about approaches to OHSMS hazard identification and risk assessment.

EHSMS Management Review – Making it Real

Introduction

Skillful performance of concise management review meetings can dramatically improve management’s perception of the value of the EHSMS. The key to successful management review is distilling important information about the performance of the EHSMS to a point where it is actionable by management and presenting this information in a timely manner. Here are a few Does and Don’ts for successful management reviews:

Does

• Use regular periodic general business review meetings to present selected EHSMS inputs.

• Make sure the inputs are concise, well thought out and include recommendations for action.

• Include financial information such as Return on Investment calculations with recommendations.

• Keep a log of the dates each of the required inputs was discussed and records of the details of the presentation and any outputs from management.

Don’ts

• Conduct management review infrequently (only annually).

• Forget to record the results (outputs) of management review

• Ask management what they think should be done. It is the management review presenters’ responsibility to make EHSMS recommendations for improvement upon which management can act.

• Try to cover everything at once.

Discussion

The following is a brief discussion the Management Review Does:

Use regular periodic general business review meetings to present selected EHSMS Management Review inputs.

Good managers and leaders recognize that organizational change happens in increments. That’s why most organizations conduct regular periodic meetings of the management staff to review important attributes of business performance such as production issues, staffing, financial performance, new predict development and sales. These meetings are used by management to keep in touch with many of the key performance indicators management uses as a basis for deciding what incremental interventions are needed to keep the business healthy and prosperous.

These meetings are a great opportunity for the EHSMS manager to briefly get top managements attention about specific important EHSMS issues and propose potential incremental changes to improve performance. The notion that EHSMS Management Review is only needed infrequently (for some organizations only annually) can result in significant delay in management’s recognition of potential improvement opportunities and delay in realizing the benefits of the improvement. More frequent reviews also keep management informed on the progress of execution of recommended changes (outputs of management review).  Figure 1 is a example of how you might create a schedule for performing portions of management review during regulator business review meetings.

Figure 1

Figure 1

If management review is only conducted infrequently top management at the organizations will not know if the interventions they have approved are effective. It may be another year before they get any feedback on whether the recommended improvement was implemented and if it had an effect on performance.

Make sure the inputs are concise, well thought out and include recommendations for action.

Doing more with less is the reality of businesses today. Human resources including management resources are scarce and top managements time is a precious commodity. Therefore it is important to be able to quickly cover the important points about an EHSMS issue  in a way that will result in an action (a decision by top management). Make sure that at recommendation for action is included at the end of a brief presentation of the facts of a particular issue. If you simply present the facts of an issue without a specific recommendation management may not act. Proposing a specific recommendation as a potential solution to an issues encourages management to make a decision.

Include financial information such as Return on Investment calculations with recommendations.

Improvements in the EHSMS are good but, if they require an investment of financial or human resources management will likely care a lot about what they will get out of that investment. Putting a monetary value on the benefits in terms of return on investment helps management justify it. Proposed investments in the EHSMS should cash flow within the time period that management would consider for other investments.

The ROI for recommendations for improvements in environmental performance are easier to calculate than health and safety improvements because they are more measureable. Re-lighting a warehouse with energy efficient bulbs is an good example because it is fairly easy to calculate how long it will take to recover the investment.

Calculating ROI for Health and safety improvements is a bit more difficult because it involves estimating the relative risk of something bad happening and the consequences of that event. When presenting health and safety recommendation you should include a recommendation for what risk level should be acceptable and what it will cost to achieve that reduced risk level. Management then needs to decide if the recommend risk reduction is acceptable and worth the investment of financial or human resources.

Keep a log of the dates each of the required inputs was discussed and records of the details of the presentation and any outputs from management.

Records of the results of management review are valuable to show evidence of management commitment to the EHSMS. They can be used to show external auditors the organization is conforming to the requirements of ISO 14001 and OHSA 18001 clause 4.6. They may also be valuable should an incident occur that is investigated by a regulatory agency (USEPA or OSHA) or if there is a civil action involving an injury case.

A matrix or table like  Figure 1, showing what parts of the EHSMS were reviewed when (during regular business review meetings) can help you retrieve the records of what was discussed and what decisions were made. Keeping a brief accurate record of the issues discussed and the outputs from management and then linking these records to the dates on the matrix will help in locating specific management review meeting minutes when they need to be retrieved.

Conclusion and Recommendation

The management review part of an EHSMS is a powerful tool which enables incremental improvements in EHSMS performance. Done with skill, management review can improve the perception by management of the value of the EHSMS. Integrating the management review function with normal business review meetings helps management address import EHSMS issues in a timely incremental fashion.

Take a look at your management review process and decide if it is helping sustain the continual improvement process and the effectiveness of the EHSMS. If not, maybe it is time to think about re-engineering the management review process to make it more relevant to the organizations performance improvement efforts.

Approach to QMS Registration Audits

 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. 

Integrated Management Systems Internal Auditor Training

Recently we were asked to deliver an encore edition of a four day IMS Internal Auditor training course for one of our clients. They are a large manufacturing facility surviving the recession and gaining market share, in part because of their robust management systems. This organization has chosen to invest in the competence of their internal auditor staff,  recognizing the value and importance of the “checking” part of their management system.

The course is three days of intense classroom and actual on the floor auditing. This learn-by- doing course includes review of the similarities and differences of the ISO14001, 9001 and OHSAS 18001 standards and includes numerous activities. Actual department audits are performed, findings written and a closing meeting with management is held at the end of the course actual audit. Student competence is evaluated during the course through observation of each individual’s performance by the course instructors.

This updated version of the course includes a new section focusing on the Lean Six Sigma programs used at the facility and what internal auditors need to know to ensure the gains made from Lean Six Sigma projects are sustained by the organization. The fourth day of the training is targeted to the more experienced Lead Auditors and helps develop leadership skills and attributes. The course includes a test at the end to check the auditor’s knowledge of the subject matter and to help confirm that the auditors possess  adequate competence to perform value-added effective IMS audits.