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.
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 site;
- 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 outcome.
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.