Common ISO 14001certification pitfalls
To well managed companies, ISO 14001 is what they do every day; it’s common sense resource and materials management. If they analyse what they do to maximize long term profit and minimise waste; to ensure regulatory compliance; to ensure that what they do now will not have a detrimental affect on future generations, rather than pursue the short term, short sighted profit goal, then the chances are they will get certified easily.
Companies who struggle with ISO 14001 are generally those who look for shortcuts to the “Plaque on the Wall in Reception” that allows their business to continue! They generally send their Quality Managers on a 5-day environmental course and expect them to understand the intricacies of environmental aspect identification, Global warming, ozone layer depletion, Carbon and landfill taxes etc. When they return from the course they are expected to implement ISO 14001 and get certified within six months of the course.
This is the first pitfall, insufficient training and understanding of the requirements of ISO 14001. Quality or Safety Managers need to go on at least 2 courses, an IEMA registered 5 day environmental auditing foundation course to understand how to train their eyes, ears and noses to become environmental detectives, so they can easily identify and understand what environmental aspects are. This will help Quality Managers to shift their focus from satisfying customers and Safety Managers away from risk and hazard assessment. After this training further training on how to implement an EMS (environmental management system) should be given. Support during this phase should be provided by an experienced EMS consultant, who has a successful track record in assisting clients to achieve ISO 14001 certification.
The next stage should be to agree a practical period to allow EMS implementation, bearing in mind that it will take at least 3 months to build the system and train all staff, another 3 months to produce the necessary records to show the system is working, and then another 3 months to complete the certification process and receive the certificate. Companies have done it in less time, but the pressure on the management representative some times shows!
The best stating point after training is to conduct an initial environmental review. This basically establishes where you are with respect to the requirements of ISO 14001. It also identifies how you do things and what your company culture or work style is. Most companies address some of the requirements in their every day operation, but don’t realize that what they do could meet the standard’s requirements because the “labels” are different. Poor consultants will skip this stage by offering the client an off the shelf solution. So the unsuspecting client falls for the easy implementation option (from the consultants point of view), but ends up with a system which is purely an add on to their existing methods, which increases everyone’s work and adds no value to day to day management. So the message is tailor the system to fit what you do, and not tailor what you do to fit the system.
Aspects identification is the area where real environmental knowledge and skill is required, so if you don’t know how to do it buy it in.
Staff training is an area of concern re cost: how much training; how often; what material? You should focus on what your staff need to know to do their job and comply with the EMS requirements, so don’t waste lots of time showing the “Amah” the clause structure in ISO 14001, when all she needs to know is how to segregate your waste! Remember that ISO 14001 is a very practical and visible management system, so the auditor will focus on results, not paperwork, by walking round your site and talking to front line staff.
Another area which causes most concern is monitoring and measurement, especially when related to environmental licenses. Firstly, what does the license mean and how can you comply with the requirements. Get someone to explain to you in simple terms what the license means and then monitor regularly (this means as often as your wife checks your bank balance!).
Much time is spent arguing whether design should be included in your Quality Management System (QMS), however, for EMS, Design or Change Management is always included as it leads to preventive action.
Internal audits can be a source of problems as the requirements for ISO 14001 require the auditor to check if the client has made reference to ISO 14010, 11 & 12 (the EMS auditing standards). The guidance standards detail how to do an EMS audit and who should do it. The overall requirement is to be able to show the auditor exactly what questions you asked, which evidence you checked and what your conclusions were. Remember the more reliable your internal audit is, the less the auditor will have to do. Another point is that if your QMS audit approach is poor you will have to improve it as the requirements for EMS are mirrored for QMS, in the new released joint auditing standards ISO 19011.
Secondly, while talking about internal audits the most common pitfall is carry out the audit but not closing out the audit findings before the external audit. Also remember that the audit frequency should reflect the environmental impact from the activity. So if you have a problem department or site, then audit them to death and close out all the findings promptly to ensure improvement.
While on the subject of improvements, ensure your objectives are in line with your environmental policy. Don’t expect the auditor to accept an objective to reduce environment prosecutions by 50% if you have committed to comply with all relevant legislation! Similarly don’t have an objective to train all staff on their part of the EMS, 6 months after the certification date, because they are expected to be trained and competent before certification.
Finally, ensure you’ve conducted your emergency drills before the certification audit, otherwise you will have problems convincing the auditor that you are prepared for all situations. There are more examples, but these are the most common.
Remember the certification body auditor is there to find out what is working well and encourage you to get certified, not to punish you for things you have not done, so it’s in your own interest to find a competent certification body. Don’t just accept the lowest price (if you pay peanuts, you’ll employ monkeys!). Remember, an EMS, if implemented properly, will help you reduce cost, so find out if the certification body employs real, experienced environmentalists who can help you succeed. At HKQAA we pride ourselves on our ability to add value to your EMS and are pleased to say, “WE ARE HERE TO HELP”.
Dr Ian T Nicolson
CChem MRSC, CEng MIChemE, AMIEMA
IEMA Registered Principal Environmental Auditor and Technical Advisor of HKQAA