EMS – a fitting assessment
Environmental management should not be a bolt-on bureaucracy. Performance-based EMS assessment, according to David Turberfield, URS Verification, takes the pressure off documentation and focuses on practical measures to combat environmental risk.
The traditional approach to ISO14001 assessment has evolved from existing management
system assessment techniques. This generally involves the auditor carrying out
a formal document review where the organisation’s Environ-mental Management
System (EMS) manual, procedures and records are assessed against requirements
of the standard.
This approach, although very widely applied, has a number of disadvantages:
- by focusing on documentation, the non-conformities report tends to push the
facility’s environmental professionals back into the office to re-write documentation
– time that would be better spent dealing with actual environmental issues on
- it can lead to the development and maintenance of a ‘paper palace’ with the
bulk of activity being directed at the bureaucracy of environmental management
rather than, and often at the expense of, actual environmental management;
- staff can become engulfed by paperwork, which in turn generates frustration
and negativity towards the initiative;
- the EMS effort can become cyclical with short periods of intense activity
during the weeks immediately proceeding an assessment as the facility updates
and validates documentation not visited since the previous assessment; and
- managers employ a very broad range of techniques and tools to get things done,
one of which is to write a formal written procedure. The assessment activity
focusing mainly on documentation fails to provide the critical understanding
of how things are really done and how they may need to be done differently.
The performance-based approach to EMS certification is designed to move the
focus of effort that goes into ISO14001 away from the bureaucracy and into real
environmental improvement. This approach aims to deliver the fundamental principles
of ISO14001, which are: the control of environmental risk; compliance with environmental
regulations; and ongoing improvement in environmental performance.
An effective EMS provides both site and corporate management with confidence
that the likelihood of a serious incident, and the disastrous legal, financial
and public relations issues that often follow in their wake, is minimal. To
be of value, an ISO14001 certificate should be an independent evaluation of
the EMS confirming this on an ongoing basis.
The performance-based approach focuses on the site assessment and the identification
of environmental risks and compliance issues. Where an observation or finding
is made, causal analysis techniques are used to determine the root cause of
the issues under discussion.
This involves very sensitive interviewing and detailed investigation of documentation
relating to management of the environment including licences and permits, emissions
data, drainage, site and vicinity plans, etc. In order for this approach to
be effective, the auditor and the facility personnel have to work very closely
to gather and analyse the necessary information.
Site inspection is followed by a comparison of existing management mechanisms
employed in core operations with those developed for environmental management.
Environmental management should not be a bolt-on bureaucracy.
Where the root cause of an observation or finding made on site indicates an
underlying weakness in environmental management, the assessment aims to identify
existing management mechanisms that could deliver the required environmental
In this approach, although the assessment has to ensure that the organisation
has the documentation specifically required by the standard, review of documentation
is not the focus of activity. Specific documents, i.e. procedures, operational
instructions, work instruction, records, etc, are not referenced in the improvement
report as fundamental weaknesses in the management of the environment unless
they really are.
The performance-based improvement report is written by the auditor and facility
personnel together in the following format:
- Observation – a description of the observation or finding made;
- Implication – the actual or potential implication of the observation or finding (risk, compliance or conformance). If there are no implications then there is no value to be gained
from causal analysis.
- Causal Analysis – a summary of the causal analysis investigation, how the
root cause was eventually determined and the actions the facility propose to
take to address it.
- Clause of ISO14001 – Reference is then made to the clause of the standard
to which the cause of the issues relates.
All organisations that apply for certification are eager to pass the certification
assessment and will do what needs to be done to satisfy the certifier and obtain
the certificate. If the certifier is going to focus the certification assessment
effort on reviewing documentation, then the company will respond by developing
detailed documentation that will pass inspection.
If, on the other hand, the certifier focuses its effort on assessing the way
the organisation goes about controlling environmental risks and ensuring legal
compliance on the ground, then the company will have to focus its effort on
understanding and controlling its environmental risks and ensuring that it is
in compliance with the law. In terms of improvement in environmental performance,
the latter is arguably more effective in delivering tangible results.