Understanding Green Tier Audits

The Wisconsin Department of Natural Resources Green Tier program has requirements for participants to perform different types of audits of their Environmental Management Systems (EMS). Understanding these types of audits and who can perform them will help ensure compliance with Green Tier. The types of Green Tier audits are:

  • EMS Internal audits
  • EMS Outside Audits
  • Regulatory Compliance Audits

Types of Audits and Frequency

EMS Internal Audits

Internal audits can be performed by the participant themselves or by independent auditors. These audits are then used as part of the management review process to help leadership evaluate the performance of the EMS and to decide if any changes are needed to improve it. They must be documented, performed at least annually and conducted by competent objective auditors.

Outside Audits

Outside audits are performed by independent auditors that have been approved by WDNR to perform these audits. Tier 1 participants must perform these audit at least every 3 years. Tier 2 participants need to have an WDNR approved auditor perform these audits at least annually.

Compliance Audits

Compliance audits are different than the Outside Audit described above. These audits check that the organization is meeting the USEPA, WDNR and local legal requirements. These include requirements for emitting pollutants to the atmosphere, water, solid and hazardous waste disposal. Tier 2 participants need to perform compliance audits at least annually and report the results to WDNR. These audits can be internal audits or performed by other independent auditors.

Why Does Green Tier Require Audits?

The Green Tier Law is based on the requirements of ISO 14001 which also requires periodic audits of the EMS. ISO 14001 is itself based on the principals of continual improvement (PDCA). Audits are the checking part of the PDCA cycle.

Who is Qualified to Perfrom External Audits

Only WDNR approved Green Tier auditors are qualified to perform external audits. Green Tier participants should confirm that their auditor is on this approved list. Participants should do this even if they are using an ANAB accredited ISO 14001 certification body to perform their external audits. If you have any questions about Green Tier audits, who is qualified to do audits or want to know how to get the most out of your audit contact us for at kalehner@envcompsys.com or use the form below.

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CorrectTrack 2.0 Release Soon

Environmental Compliance Systems, Inc. (ECSI) is pleased to announce the release of CorrectTrack 2.0 soon.  CorrectTrack 2.0 marks a significant improvement in the applications ability to provide important ISO management system performance information quickly to users.

Over a decade ago ECSI began to explore digital tools to enhance our ISO consulting, auditing, and training practice.  We were looking for a cloud-based application that helps our clients and others implement and operate ISO continual improvement management systems.   Being unable to find a suitable off the shelf solution we began adapting available open-source bug tracking software.  The objective was to provide a systematic corrective action tracking process that was superior to existing Microsoft access database and excel spreadsheet solutions. The list of organizations using CorrectTrack has now grown to over 40 organizations and 450 individual users.  To our knowledge CorrectTrack continues to be the only cloud-based application designed exclusively for ISO 14001, 45001, and 9001 management systems.

CorrectTrack 2.0 has better dashboard user experience and more flexibility to let users configure it to their specific needs.  Users will have access to all the application features including:

  • Permissions based user access and functionality.
  • Approval gate process for corrective action investigation, verification, and closure
  • Risk management module for all ISO management system standards including 9001, 14001 and 45001.
  • Internal audit planning and follow-up.
CorrectTrack 2.0 Dashboard and Landing Page

As part of the CorrectTrack 2.0 rollout we are offering a free consultation to ISO management system experts and representative to explore how the application can benefit you ISO management system and improve your organizations occupational health and safety, environmental and even quality performance. 

Contact us for more information on how CorrectTrack 2.0 can help your organization’s ISO management system performance.  If you like what you see, we will help you get started with a free application trial period without any obligations or fees.

Join US at the 2022 ASSP Risk, Health & Safety for All Conference.

We are looking forward to seeing you at the 2022 ASSP Risk, Health & Safety for All Conference Thursday, September 29 & Friday, September 30, 2022 at The Ingleside Hotel in Pewaukee, Wisconsin. With two days of educational sessions, workshops, and panel discussions, this event is full of super rich networking and collaboration opportunities. More

Preview our Presentation

Please be sure to come see us at session #12 where we will be sharing information on Semi-quantitative Risk Analysis – An OHS Leading Indicator. Here is a description of the presentation:

OHS Managers need to find good ways to predict and influence future OHS
performance. These predictors of OHS performance are referred to as “leading indicators”. Semi-quantitative OHS risk analysis is now being recognized as a good leading indicator of OHS performance. This session describes how semiquantitative risk analysis is used as a leading indicator of OHS performance

Come see us at our booth at the show to say hello  or for a quick demo of the CorrectTrack app.. Be sure to put your name into our raffle that will award a lucky winner at our ever-popular beer tasting on Thursday evening and taste premium beers with one of the Tyranena brewers..

We are Presenting at Wisconsin Safety Council Safety 2022

Join us at the conference. We are presenting on E-Tools for OHS Risk Management. Learn about how cloud based app and relational database are emerging as essential tools for EHS Managers. We will cover how to use these tools to:

  • Use a database to record the results of a JHA
  • Preform hazard risk reduction tasks
  • Perform audits of risk controls
  • Use e-tools to perform corrective actions
  • Communicate to leadership on EHS performance

Covid 19 Pandemic – How we Adapt

Covid made us change how we work. Virtual meetings are the new normal when connecting with others and conducting business. Our certified training courses, internal and third party audits are conducted virtually with great results. A positive is dramatic reduction in effort and resources invested in travel to and from our clients or public courses. The negatives include more difficulty in performing audits on specific processes. Hand held devices do not show what is happening on the manufacturing floor well. They are also prone to loosing connection due to poor WiFi in some areas of the facility.

Contact us to learn more about how we are adapting and what we can do to help your organizations as it adapts to the new normal of Covid 19.

Kevin Lehner
President – ECSI
October 18, 2020

Our Thoughts on “Is ISO Registration the Answer?”

A long-time professional college “The Honorable Scott Weyburn”, recently posted an interesting question focusing on benefits of ISO 9001 registration.  I posted a response that prompted Scott to ask for more so here it is.  Here is a link to Scott’s post which you might want to read first.

Understanding the Problem

The cause of the problem is easy to understand but difficult to correct. In my three decades performing nonfinancial audits for CBs if have found the CB customers primary interest is in sending a signal of sustainability to customers and other interested parties.  Improving sustainability performance is subordinate to that perceived imperative.  As a result, the organization focuses on passing the audit, not on having an effective management system.  Investment is in readying for the audit not on the resources of an effective system.  This is partially due to naivety and a lack of readiness in leadership in the organizations. 

It is also due to financial tension within the organization.  Investing in audit readiness only cost less than skillful implementation of an effective management system.  Leadership calculates “If all I want is certification for messaging and developing a MS with that goal is cheaper than an effective system, why would I invest in an effective system?”.  Leaderships misunderstanding is almost excusable considering the misrepresentation bombardment from CB’s and AB’s that their certifications and accreditation’s are evidence of system effectiveness.

Audit Services as Commodities

Another reason the certification process is failing is organizations seeking certification services perceive them as a commodity to be purchased from the lowest bidder.  They do not understand certification audits are a professional service where auditor and CB competence are critical to obtaining a return on their certification investment. 

To be competitive CB’s in the past would reduce the number of audits days and thereby reduce the cost of their service over their competitors.  IAF implemented MD-5 to try to control this audit day downward trend.  MD-5 is a complex system for determining audit days that was of some help early on.  However, as time went on CBs recognized that the only way to be competitive was to reduce the day rates for auditors.  Subsequently there has been a continuing downward spiral in compensation of qualified auditors, especially for contract auditors with no employment benefits. 

Many experienced auditors like myself have subsequently reduced the number of audits we perform for accredited CBs doing only enough to remain competent for purposes of certification.  The CBs now rely on inexperienced, inexpensive, and often incompetent auditors to perform audits on their behalf.

ABs Playing a Role

The ABs have also found themselves in a difficult financial conundrum.  There has been much consolidation in the CB business reducing the ABs revenue streams.    They recognize the threat to their clients, that major findings of auditor incompetence would bring, and are reluctant to issue meaningful nonconformities that compel change.  The incentives created by the ABs for CBs to improve their performance are more prescriptive and lead to “lipstick on a pig” corrective actions that exacerbate the problem.

Conclusion

These are tough problems to solve that cannot be wrestled to the ground overnight.  The financial assurance industry addressed similar problems with Sarbanes–Oxley Act of 2002 as well as in the Accounting Standards Codification issued by the Financial Accounting Standards Board (FASB).  The best chance of fixing the underlying problems with assurance in the non-financial sector is to enact similar legislation which is unlikely to happen in the foreseeable future.

WDNR Green Tier – Internal Audits and Corrective Action

WDNR Green Tier Internal Audits

The WDNR Green Tier program requires participants to conduct periodic “outside” EMS audits to check that the system is functionally equivalent to ISO 14001:2015.  By law, the minimum frequency of these audits is once every three years for Tier 1 participants and annually for Tier 2 participants. 

Many organizations choose to perform WDNR Green Tier audits more frequently than prescribed by the Green Tier law.  Longer than a year between audits result in increased risk to the organization.  Postponing an annual physical from your doctor increases the risk that a medical condition will becoming a bigger medical issue.

WDNR Green Tier audits also provide important information to leadership.  Reviewing Green Tier audit findings during management reviews allows leadership to evaluate how the EMS is functioning and if it is achieving the intended results. Leadership may miss important information when it reviews the results of audits only every three years.

Organizations that invest in their WDNR Green Tier audit program have better performing EMS’s and get a better return on their EMS investment.  ISO 19011:2018, Guidelines for auditing management systems provides guidance for organizations wishing to improve their EMS audits.  This guidance includes:

  • How to establish audit programs
  • How to conduct audits and report audit results
  • What competencies auditors need to possess
  • How to evaluate auditor competence.

Using the results of WDNR Green Tier Audits

WDNR Green Tier EMS audits evaluate audit criteria against audit evidence. Performing WDNR Green Tier audits ensures that “what should be is” and “what should not be is not”.  Examples of audit criteria are requirements of Green Tier functional equivalence, compliance obligations such as permit requirements or requirements such as WDNR universal waste and hazardous waste regulations.  They can also be internal requirements the organization has set for itself.

A robust EMS audit process and procedures coupled with effective corrective action process to address audit findings is critical to the effectiveness of am EMS.  If the audit process or the corrective action process is weak the EMS may not be able to achieve the intended results of the EMS.

WDNR Green Tier Audit Corrective Actions

Green Tier audits are fundamental to superior environmental performance, but audits alone do not make changes that improve performance.  Audits simply identify conformance and nonconformance to the requirements of Green Tier and the organizations internal requirement for the EMS. 

Audits can be good news or bad news.   If an organization is performing audits and find nothing but “good news” that is not especially noteworthy to leadership.  Things are going along well, according to plan, and there is no identified need for action. When audits find nonconformances or bad news, this is good news to leadership because the audit has identified things that need to be fixed.  

If organizations are either not performing effective audits or no audits at all this is bad news for leadership.  Leadership has no way of knowing if the EMS is performing as planned.  “No news” is bad news.

Audit nonconformance findings are good news and a source of EMS performance improvement.  Audit nonconformances are not evidence of failure or reason to find fault. Doing so will create fear of the audit process within the organizations and increase the difficulty in gaining employees trust and cooperation with the audit process.

To benefit from the results of audits organizations also need to fix the nonconformance problems the audits discover. Performing audits and then being unable to correct the problems discovered is often a bigger problem than not performing audits at all.  An example is an audit of regulatory compliance status that discovers a potential noncompliance.  Uncorrected findings later discovered in a regulatory agency compliance audit could result in enhanced “knowing and willful” criminal penalties.  Finding a potential noncompliance problem and not fixing it is worse than not finding it in the first place. To reduce risk, organizations need to take corrective action on audit findings in a timely fashion.

Some organizations struggle to get traction on their corrective action process for two primary reason.

  • A clear process or workflow for performing corrective action has not been defined and or communicated by the organization.
  • The organization has not established a systematic way to keep track of and report on if and how the nonconformance are being addressed.

WDNR Green Tier Audit Corrective Action Workflows

Corrective action workflows for audit nonconformance should be a team effort.  Teams should follow several sequential steps collaboratively and reach consensus on each stage in the workflow. The last stage of the workflow is verification of effectiveness of the corrective action.

This team approach is similar to the collaborative product design process used by industries to develop products. The design process has desecrate points in the process called gates. Design teams agree that each step was completed before the design process can progress through the gate to the next stage

The purpose of this design review workflow is to ensure the design process is proceeding in a systematic fashion and to minimize the potential for design flaws that will become apparent in the production or use stage of product or service.

Figure 1 is an example of a corrective action workflow with approval gates and stages.

Corrective Action Workflow with QApproval Gates
Corrective Action Workflow with Approval Gates

Gates separate some of the stages in the corrective action workflow.  The number of approval-gates in the corrective action process can vary depending on the organizations’ needs.  Stages in the corrective action workflow can include:

Stage 1 – New (Contain and Assign)

Recognition of the problem is the first step in the corrective action workflow. Recognition can occur as the result of an audit or incident.  How the workflow proceeds after recognition depends on the gravity of the problem or incident encountered.   The team leader or gate keeper needs to quickly decide what type of problem it is such as:

  • Easy to Fix – We understand the problem cause and we can just fix it because it is unlikely to recur
  • Not so easy to fix – We do not fully understand the problem but believe that the cause and solution can be discovered without commitment of substantial resources at this stage.
  • Difficult to fix – This type of problem needs significant resource (horsepower) to address it with skill. 

The preliminary evaluation will determine the size and competencies of the team needed to address the problem.

The team should consider Immediate steps to contain the problem (stop the bleeding) and what that containment should be.  Placing lables and dates on the universal waste containers corrects the audit finding.The person assigned to the corrective action task should not delay implementation.

Stage 2 – Investigate (Cause and Corrective Action)

Cause analysis

Putting a band aid on the problem with a short-term correction alone will not address the underlying problem cause and the nonconformance is likely to recur.   Determining the cause of a problem is necessary to find a solution that fixes the problem and prevents recurrence.  The team should investigate why the problem happened in the first place. 

Root cause analysis is a huge topic and there are many approaches to doing a cause analysis, but sometimes asking “why did that happen?” several times can help identify the underlying cause of the problem (5 why analysis).  Other problems can be more complex and require more horsepower than a 5 why analysis can deliver.  These types of problems may need more sophisticated cause analysis techniques such as Six Sigma (DMAIC), 8 Disciplines (8D) or others.

Corrective Actions

The root cause of the problem helps the team discover an effective corrective action that will prevent the problem from recurring. The team should reach consensus that the proposed corrective action is appropriate to the cause before the corrective action is implemented. This will improve the likelihood that the corrective action will fix the problem in a way that it will not happen again..   

Corrective action solutions that are based on one individual’s perception of the root cause and how to fix that problem often oversimplify both the cause and the solution.  The tendency is for individuals to hurry the process and close the nonconformance as quickly as possible.  This leads to weak root cause analysis which in turn compromises the selection of an appropriate corrective action. 

If the corrective action process is not monitored in a team setting the assignee is more likely to close out the issue (get it off their desk) as soon as possible.  A team approach to the corrective action process that use approval-gates can help avoid this consequence. Approval-gates encourage robust cause analysis.  

The following is an example of poor cause analysis and proposed corrective action for the audit finding that universal waste containers were not properly labeled and dated.

  • Proposed Cause –  “The employee had not been trained in how to properly package and label the universal waste”. 
  • Proposed Corrective Action:  Train the employee in how to properly package and label universal waste. 

This cause analysis simply repeats the finding.  It does not describe why the problem happened in the first place and the proposed corrective action is more of a correction than a corrective action.  Implementing this action will not ensure that the same problem does not happen again.

Root Cause Analysis

Figure 2 shows the results of a more appropriate cause analysis of the universal waste packaging and labeling nonconformance.

Example of 5 Why Cause Analysis
5 WHY Analysis

Once the root cause is identified an appropriate corrective action can be proposed that will prevent it from happening again.

Often there are several options for corrective actions that fix the problem in a way that it does not recur.  Some might have potential to be extremely effective but are costly to implement.  An example might be to outsource the universal waste management to a contractor that comes to the site daily to check that the universal waste is being management correctly.  This is highly effective and can transfer some of the risk of universal waste management, but it is expensive to implement.  Before the corrective action is approved the team needs to decide if the proposed corrective action is appropriate for the cause.

An appropriate corrective action decided by the team for this problem and cause might be something like:

  • Leadership will direct the HR department to develop a training matrix that shows competence required for all jobs including temporary fill in positions.
  • The HR department will develop a process(es) that require(s) employees to demonstrate competence to do a job before the employee can be assigned to that job including temporary fill-in positions.

The team should reach consensus that the proposed corrective action is appropriate for the root cause before it is implemented.  Once approved the actions should be implemented without delay.

Stage 3 – Perform (Corrective Action Implementation)

The team implements the corrective action after it is approved by the team and its leadership.  One individual can implement a simple corrective action quickly. Complex problem solutions may require development of a project plan that assigns team members tasks. Task assignee’s need to accomplished these task by established dates. The team monitors progress on the tasks and periodically reports to the team leaders.

Stage 4 – Verification of Effectiveness

Verification confirms that the agreed upon corrective action was implemented as planned.  It also confirms that the corrective action implemented was effective and fixed the problem in a way that it will not happen again. 

Corrective action verification is usually performed by internal or external auditors during regularly scheduled or other audits.  Others in the organization or on the team can perform the verification but it is important that the verifier be independent to the implementation process or the area where the verification is occurring. 

Stage 5 – Closed

Team can close the corrective action after it has been verified. The team may need to invest additional effort if the verification finds that the corrective action implemented did not fix the problem. The team may need to re-investigate the cause and to re-propose and implement another corrective action.

Communicating and Tracking Corrective Action Status 

A significant stumbling block that organizations sometime encounter when addressing nonconformances is the absence of a method to communicate and track the status of completion of the corrective action.  Information about corrective action status has traditionally been paper based or electronic.  These systems assign a corrective action task to someone to investigate and complete. 

The team leader passes the physical or electronic copy of the corrective form to team member responsible for investigating the cause and proposing a corrective action.  Then the paper or electronic copy is passed to other team members to add information or it is returned to the team leader for review and approval.   

Assignee’s can misplace paper or electronic copies of corrective actions.   Paper-based tracking systems require large three ring binders to store the completed corrective action forms and associated supporting documentation such as pictures or other evidence of completion of the corrective action.  Electronic documents are often individually stored in folders located on the organizations servers or in the cloud.

With paper-based systems, communicating the overall status of corrective actions to leadership requires a labor-intensive process of thumbing through the three ring binders and manually recording the status of the corrective actions.  Individual documents stored on servers or in the cloud have similar problems.  Sorting through individual folders and files takes time to to find important information about the corrective action program.   Use of electronic spreadsheets can help here but create other problems that limit the effectiveness of this solution

Corrective Action Tracking Database Apps

Industry 4.0 revolution will soon fundamentally and significantly change almost all business. This revolution is helping organizations store data optimize equipment and operations using the cloud environment.   Organizations will be able to access enormous amounts of information with a click.  Affordable cloud-based applications that track corrective action progress progress of are now becoming available to all types of businesses. Some of these application are easy to use and allow quick access to trends that inform management decisions.

The heart of these cloud based applications are databases that organize and store information.  They help communicate the status of corrective actions to team members and leadership.  These applications make it easy to monitor the approval-gate process and communicate with team members via automated emailing functions when the status of a corrective action changes or is approaching a due date.  Correcttrack.com is a cloud based application that helps organizations keep track of Green Tier audit findings and improve the effectiveness of the corrective action process.

Conclusion

WDNR requires Green Tier participants to periodically audit their Green Tier EMS.   Audits confirm the organization has established and is operating a “Functionally Equivalent” EMS that results in superior environmental performance.  They are the critical “checking” part of an effective functionally equivalent EMS.  If performed with skill the audit results can provide important information that the organizations leaders need to determine if the EMS is achieving its intended results. 

Ensuring the results of audits are addressed in a timely fashion is critical to an effective EMS.  This is especially true for nonconformance and noncompliance audit findings because findings that go unaddressed or with poor corrective actions increase the risk to organizations than if audits had not been done at all. 

ISO 45001 TC 283 – International Meeting Kigali, Rwanda

The ISO 45001 Technical Committee TC 283 is meeting in Kigali, Rwanda the week of October 6-12, 2019.  The meeting will start with a plenary of all attendees to update national members on TC 283 developments.  Task Groups (TG) and Work Groups (WG) will meet independently to work out the contents of several new work items that in are in progress including:

  • TG1 – Communications
  • TG3 – Revision of the High Level Structure (Annex L Appendix 2 & 3)
  • WG2 – Psychological Health and Safety at the Workplace
  • WG3 – Implementation Handbook

The TG3 discussions on revision of the ISO High Level Structure will focus on issues that have been encountered by users of ISO 45001 with respect to:

  • The definition of risk as it applies to an OHSMS
  • The relationship between risk and opportunity and the traditional OH&S discipline specific terminology ‘Hazards and Risks’
  • Outsourced processes and how these to the OH&s discipline.

Comments are welcome here on opinions of changes to the HLS that will benefit the discipline specific ISO 45001.

Auditing ISO 45001:2018 – 5.4 Consultation and participation of workers

Note. I want to be clear upfront that my intention is not to discredit the contribution organized labor made to the development of ISO 45001:2018.  The point I make here is that they had a significant impact on the requirements in certain sections of ISO 45001:2018.  This fact may help inform users about the intent of the requirements for purposes of implementation and conformity assessment. 

Clause 5.4 of ISO 45001:2018 discusses requirements for consultation and participation of workers and is the result of an interest groups desire to ensure their constituents were give certain rights to have influence over the organizations OHSMS.   Organized labor got a symbolic win here for their constituents but does this additional language add value to the standard or simply create unnecessary complexity and confusion for users of the standard?

As an auditor my approach would be to check if the workers themselves believe that their opinions about the OHSMS have been considered in its development and implementation.  The best way to do this is to ask them directly. Here is a line of questioning I would use to get objective evidence of conformity to the participation and consultation requirements in 5,4 of ISO 45001:2018.

My first question would be something like “Have you heard about the OHSMS here?”.  The answer to this question helps me get a sense of the organizations general awareness of the existence of an OHSMS.  You might have to rephrase the question to get them to understand what you are asking.

The next questions would be something like… Can you tell me about what you do as your job here and what you do to keep yourself safe from injury or ill health?  A good answer would be something like… My job is to load railcars.  I need to stand on top of the railcar and inspect it after it is loaded.  I need to wear this fall protection harness when I am on the railcar in case I accidently fell off.  The harness would break my fall and prevent or reduce my chances of injury.

The next question would go directly to participation and consultation and would be something like this.  Did you participate in any of the planning part of the OHSMS giving leadership your opinion of your comfort level with safely performing you job.  Another good answer would be something like…Yes, our entire crew participated in a hazard identification and risk assessment meeting where we went over all the job tasks and risks.  We were asked if we felt safe doing these tasks given the safety procedures and equipment that was in place.  One of the areas we raised as potentially unsafe was the absence of fall protection.  Based on that, our leadership has provided us with these ladders, harnesses and showed us how to use them.  I feel much safer now with this enhanced risk control.

Based on the results of this interview I would have good objective evidence that the intent of 5.4 had been achieved.  If most other worker interviewed had a similar tale to tell I would feel comfortable in concluding that the organizations had meet the requirements of clause 5.4 of the standard.

Of course, this line if questioning could have gone in many other directions and the answers given may not have supported a finding of conformity to varying degrees.  Auditors are certified and calibrated to make decisions during audits while considering all the evidence presented much like a judge does in a legal case.  Auditors who focus on too much detail like expecting the auditee to produce evidence of each of the 21 individual requirements of 5.4 are missing the point and need to step back and look at the bigger picture.