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If you want your EMS to mature and continue providing value over the long term, it is important to build in mechanisms that encourage continued growth while warding off complacency and loss of interest.
In last quarter's issue of Environmental Quality Management, my article entitled "Maintaining Your EMS: The Stages of EMS Development" stressed that maintaining your EMS does not mean keeping it the same over time. It means planning for the maturation of the EMS so that it continues to provide value to your organization. In that article, I noted that an EMS - even a registered EMS - will not automatically provide value to your organization over time.
How quickly your organization's EMS matures (and whether it matures at all), is dependant on your organization's plan (or lack of one) for moving the EMS forward. The first step in planning for long-term EMS survival is to recognize that an EMS typically moves through three stages over time:
In my last article, I described the timelines, goals, activities, characteristics, and vulnerabilities of these stages in detail. This article builds on that understanding by describing six critical control points which should be incorporated into your EMS implementation plan and included as part of the your organization's long-term EMS maintenance strategy.
A control point is a component of your EMS development that often is overlooked, but that merits special attention in order for the EMS to mature and provide continued value to the organization. The control points presented in this article are either related to an ISO 14001 Standard requirement (e.g., corrective and preventive action) or are attributes of project management (e.g., defining success, establishing performance measures).
Think of a control point as a potential weak link in a chain; your EMS will only be as strong as its weakest link. Failure to develop these control points will, over time, contribute to the demise of your EMS. Consider the following scenarios based on the experiences of registered companies:
How could these things have happened? Look at the control points below. Could the organizations have failed to take any or all of these steps? The six critical control points for an EMS include:
These control points (discussed below) are pertinent to all organizations. They were derived by observing the experiences of dozens of organizations (small, medium, large, industrial, and non-industrial) who have participated in EPA/NSF International pilot programs on ISO 14001 implementation (see the sidebar entitled "ISO 14001 Project Reports"). I have supplemented these data with my personal observations of registered organizations.
During the stages of EMS development, as outlined below, some control points require more time and energy than others.
Each one of the control points discussed in this article should first be considered during EMS planning, as well as early in the implementation stage. But they remain pertinent to an EMS that is already registered/in conformance.
The six control points discussed here are listed roughly in order of importance. Although the control points are related (e.g., the results of internal audits will feed into the corrective/preventive action process), they are generally not interdependent. An exception is the relationship between control points 1 and 2. You cannot develop meaningful performance metrics until you have defined what success is for your EMS, as determined by management.
If you don't know where you're going, you'll end up someplace else.
- Yogi Berra
The EMS representative for the company (the EMR) may feel that the EMS that he or she spearheaded is a success if objectives and targets are being met and internal audits reveal few nonconformances. But remember that the EMR does not define success for the EMS; top management must do this. The EMS must meet management's goals and expectations in order to continue to enjoy resources.
Be sure you have a clear and complete understanding of what the EMS must do/be/deliver in order for management to consider it a worthwhile investment. As was noted in my previous article, management's definition of success may go beyond a simply stated goal such as registration. The EMR may have to educate management on how the EMS can be utilized to meet business and financial goals.
While top management controls the EMS purse strings, another important component of EMS success is its perceived value among employees outside the team that was created to help with ISO 14001 implementation. Is the EMS seen as needless paperwork or as a system which helps manage change? Are the procedural requirements a burden or are they simply the way business is conducted? Are the objectives and targets being supported by line workers? An EMS that is not being supported by line supervisors and hourly workers will not reach its full potential.
Defining success for the EMS is most critical very early in the process, when you are devising the plan for EMS implementation. However, it is not a one-time process. The definition will change over time, particularly once registration has been achieved. Therefore, it is important to periodically reconsider your organization's definition of a successful EMS.
What gets measured, gets managed.
- Anonymous
Performance measures reflect the quantitative and qualitative results of an EMS; they are used to track progress toward the goals defined by management (see control point 1). EMS performance measures are often thought of as simply quantifiable objectives and targets. In fact, however, they also include qualitative measures of how larger business goals -such as reducing liability or improving public perception - are being supported.
Performance measures are the yardstick management uses to determine the value of the EMS. However, do not expect management to develop a set of performance measures in the beginning stage. Prior to EMS development, management often views the environmental performance of their facility in terms of regulatory violations or fines. Therefore, determining what the performance measures should be will rest with the EMR.
Determining EMS performance measures requires some creative thinking on the part of the EMR. Gathering data for performance measures may require the purchase of new software or the development of new processes for collecting data from parts of the organization outside the environmental function, such as purchasing, maintenance, shipping, or sales.
In the beginning stage of EMS development, the benefits of the EMS center on success in meeting objectives and targets that tend to be simple - such as the amount of metal and office paper recycled and the number of pallets re-used. Many companies do not want to miss a target, so they set ones that are very modest or that are not measurable. While there is nothing wrong with this approach, you should recognize that it will work for only a short time. If the EMS is to mature, more sophisticated metrics and more challenging objectives and targets will be needed in order to demonstrate value.
Do not limit your evaluation of EMS benefits to the particular objectives and targets that have been specified. For example, suppose that as a result of an EMS, your company starts to rebuild lost trust with the local community and with regulators. This may not result in direct cost savings, but it may well support other business goals, such as improved public relations. Consider another example: Was having an EMS a factor in winning or keeping a client? This is another potential benefit that might not be tied to an objective or target.
Our EPA/NSF pilot projects on EMS implementation have shown that qualitative EMS benefits can be very important (see the sidebar entitled "ISO 14001 Project Reports"). One project participant, the president of a metal finishing plant, felt that the single greatest benefit of his EMS implementation was improved communication within his plant. This included communication between both line workers and their supervisors, and supervisors and upper management.
The benefits of well-developed EMS performance measures are demonstrated by one of NSF's registration clients, Pfizer Global Research & Development - Ann Arbor Laboratories (formerly Warner-Lambert Parke-Davis Research). This progressive company was an early registrant to ISO 14001. Their environmental manager, Mike Lemon, has seen the importance of performance measures in the past three years. Mr. Lemon cites one example of how performance measures (in this case, metrics on waste management) can progress:
Our metrics are evolving. When we started the EMS, we just had information for hazardous waste generation based on what was on the manifest. This was good but not very specific to the particular waste stream. Metrics for hazardous waste generation are now much more developed and we have been able to demonstrate decreases in generation even though their facility is growing. Metrics are an important tool to communicate to management.
An ounce of prevention is worth a pound of cure.
-Henry de Bracton
One characteristic that distinguishes an ISO 14001-based EMS from most other EMS models is the strong "continuous improvement" component. Fundamental to the continuous improvement cycle is the corrective and preventive action process. Yet this important link is weak in many organizations, even registered companies.
Corrective and preventive action is logically one of the last ISO 14001 requirements a company implements. The process or procedure developed often has not been tested to any great degree at the time of registration and typically is used only in response to nonconformances resulting from an internal EMS audit.
Exhibit 1 depicts the process flow in a well-developed, effective corrective and preventive action program. Level A represents all the potential inputs (or sources of information on nonconformances) to the corrective and preventive action process. Examples of inputs include monitoring and measurement, employee suggestions, incident reports, external communications, and management review. Many corrective and preventive action programs include the results of internal and external EMS audits and compliance audits as sources of input, but do not recognize that there are other available sources of information.
Level B represents the efforts to correct the nonconformance. Unfortunately, these efforts too often are limited to the "band-aid" approach, where the immediate problem is fixed but no preventive action is taken. A more effective approach includes not only fixing the nonconformance, but also determining where else in the EMS the nonconformance may be occurring, and then determining the steps needed to prevent recurrence.
Level C reflects how the changes identified in Level B are institutionalized. A corrective action may well affect several other EMS elements, and it is important to recognize these linkages. Level C includes tracking the corrective actions to closure.
The tracking represented in Level D relates to the review of corrective actions at some point after their implementation to determine whether the actions accomplished what was intended. Level D may also include trending nonconformances to determine where a weakness in the EMS may be developing before it results in a system breakdown.
The corrective/preventive action process described above is not simply a theoretical model; it has real-world applications. Consider the process employed at Millstone Nuclear Station, part of Northeast Utilities Systems in Waterford, Connecticut. According to Gary Johnson, Millstone's environmental coordinator, the facility's current corrective action process matured over a period of about five years. All employees and contractors are encouraged to use the process and do so freely. A significant benefit of the process is that it empowers everyone at Millstone to raise environmental, safety, or other concerns in an open forum, where the source of the concern is not as important as the concern itself.
The Millstone Corrective Action Program is a comprehensive effort to identify, evaluate, and correct adverse conditions or other performance improvement items. Any nonconformances, preventive initiatives, or improvement items (environmental or otherwise) are handled through this process. The program requires that any individual with knowledge of an adverse or discrepant condition or a condition needing improvement, or with a performance improvement initiative to offer, directly report the issue for resolution.
Each reported condition is documented in a Condition Report (CR). CRs are designated as Level 1 or 2, depending on their severity, with Level 1 being the most serious. Categorization allows the extent of corrective action taken to be based on the severity of the nonconformances.
For Level 1 nonconformances, a follow-up to evaluate effectiveness is performed six months after the corrective action has been completed by the manager assigned. Level 2 nonconformances require a timely fix to the immediate problem. Level 2 nonconformances are tracked and trended through a formal process; if an adverse trend is indicated, the Level 2 nonconformances become elevated to Level 1.
Other strengths of the corrective/preventive action process include the following:
Mr. Johnson concludes:
Although the corrective action tracking system is an important part of Millstone's corrective action program, the real success of the program rests with the people who are using it. Implementing an ISO 14001 EMS and other initiatives at Millstone has helped every employee on the site understand: 1) their potential impact on the environment, and 2) that they have a responsibility to become involved in both raising and resolving concerns or nonconformances. This formal, rigorous corrective action program is an integral part of life at Millstone and is a natural fit into our EMS.
Action springs not from thought, but from a readiness for responsibility.
-Dietrich Bonhoeffer
Once the immediate goal of ISO 14001 registration is achieved, an organization may be tempted to think, "We don't need an EMR anymore. We have achieved our goal. The system will now run itself." The fact is that no system runs by itself, as I pointed out in my previous article.
While it is true that you do not need an individual or team to spend as much time on the EMS as they did during in the beginning stage, you still need someone to lead the maturation process. The EMR must help ensure that the EMS continues to function as designed (e.g., that corrective actions are completed and EMS audits done) and to champion the process of EMS maturation. By keeping an EMR in place, management conveys the message that yes, even though we have achieved registration/conformance to the ISO 14001 Standard, the EMS is still supported by management and remains a performance expectation.
How does the EMR drive the EMS maturation process? Here is another example from Pfizer Global Research & Development - Ann Arbor Laboratories. Mike Lemon, environmental manager, also serves as EMR and has lead responsibility for ensuring that the EMS works on a day-to-day basis.
A short time after ISO 14001 registration, Mr. Lemon realized that the process developed for setting objectives and targets was not working. The facility had done what most companies do - they set objectives and targets and waited for a year to see what happened. With rapid expansion, however, the facility found this process very cumbersome and unsuited to their changing work scopes.
This was a critical juncture for the facility's EMS. The system could easily have become just a paper chase, where the objectives and targets were listed on paper in order to meet an ISO 14001 standard requirement, but were not really used to manage the environmental program. Had this happened, the value of the EMS to the company would have declined over time.
To prevent this from happening, the EMR spearheaded a change in the objectives/targets procedure. With the help of his cross-functional team, he designed a system allowing targets to be changed rapidly.
That was two years ago. Today, Mr. Lemon states, "With all the expansion we are undergoing, I could never have managed it all without an EMS in place."
We have only one person to blame, and that's each other.
- Berry Beck
Regardless of the size of the facility, it is easy to allow the environmental management system to become "Joe's EMS" - meaning that one person drives the process. Joe writes all the procedures, does all the training, and is responsible for implementing most of the objectives and targets. When Joe leaves - not if, but when - the EMS, and the investment the organization has made in it, are in jeopardy.
A remedy for this problem is to keep in place the cross-functional team that was formed to help with ISO 14001 implementation. A team is a great source of money-saving ideas. It also deepens the knowledge base for the EMS, and communicates the message of the EMS (that is, continual improvement) to the shop floor, to the all-important line supervisors, and throughout the organization.
The cross-functional team can also help the EMR integrate the EMS into other facility systems, such as quality assurance or health and safety. In addition, the team can assist in determining how the EMS can support new initiatives such as life cycle assessment, and in demonstrating the value of the EMS to facility and corporate management.
Most importantly, the cross-functional team can press forward the process of cultural change within the company and reinforce the EMS message until it becomes ingrained. How important is this reinforcement? An anecdote may help here. There is an environmental regulatory inspector for the State of Michigan who routinely visits ISO 14001-registered facilities. He finds beautifully marked recycling areas and bins on the shop floor. But when he checks the dumpster outside, he finds all sorts of parts that should have gone into the recycling containers. Cultural change takes time - and reinforcement.
Spreading responsibility goes beyond just maintaining the cross-functional team. It also means developing an EMS management structure that involves all the key players. Exhibits 2 through 4 demonstrate how this management structure evolved for Pfizer Global Research & Development - Ann Arbor Laboratories.
Exhibit 2 shows the management structure in place at the time of registration. The Environmental Staff performed all the EMS implementation duties and communicated appropriate information to line management. The Environmental Staff next asked for volunteers to an environmental committee, and were surprised by the extent of the response from positions across the facility (see Exhibit 3). The Environmental Committee now reviews aspects and impacts and helps to set objectives and targets. The last step in the evolution of the EMS management structure was the formation of the EMS Management Team, composed of the facility's senior management (see Exhibit 4). The EMS Management Team receives bi-weekly updates on the EMS and reports these directly to the president of the company.
Mike Lemon, environmental manager at the Ann Arbor facility, emphasizes the importance of teamwork in developing an EMS:
Obviously, any successful EMS is the result of a good team effort. In my case there are several excellent "teams" I get to work with here in association with the EMS. These teams include my staff (Preston Smith, Kim Alfonsi), the EMS Management Team (Mark Eichkorn, Herb Rickloff), the Environmental Committee (Kim Alfonsi, Preston Smith, Todd Ziems, Fred Boyer, Joe Volstromer, Tina Bowen, Matt Polczynski, Joe Warmus, Mark Ferin, and myself) and all the line management who have supported and endorsed the program.
In God we trust. All others we audit. -Anonymous
As noted in my previous article, organizations seeking ISO 14001 registration have complete, but often immature, EMSs in place. Critical adjustments may need to be made in the EMS over the formative first two years. I often find during a first or second surveillance that there are still misunderstandings about standard requirements that have gone unchallenged by the internal audit program. A common one is, "You mean I don't need an objective for each significant aspect?"
If your organization is seeking third-party registration, request a semi-annual audit schedule from your registrar (instead of an annual visit) for at least the first few years. The number of audit days for annual and semi-annual surveillances are the same. While the semi-annual schedule interrupts operations twice, rather than once, per year, the advantages outweigh the disadvantages. After registration, there tends to be a perception that the EMS project is over and that now management and employees can move on to other projects. Semi-annual surveillances by the registrar help ensure that upper management continues to provide resources, that mid- and line management continue to support the EMS, and that employees actually use the procedures or work instructions devised.
In addition, you should space your own internal EMS audits no more than six months apart. You do not have to audit the entire EMS every six months. Instead, pick the areas to audit based on the environmental importance of the activity concerned and the results of previous audits.
If your registrar comes in once a year, schedule your internal EMS audit at the half-way point as a check. Otherwise, weaknesses, misunderstandings, or misinterpretations can continue for extended periods of time. Do not wait until two weeks before the surveillance audit to do your own internal EMS audit. This is particularly important in the deployment stage.
Once your EMS is well established, the frequency of registrar surveillance, and your own internal audit schedule, may change without a negative effect on the maturing of the EMS.
Under this standard shalt thou conquer. - Emperor Constantine, A.D. 312
The control points discussed in this article are important to ensure that employees and management see the advantages of an EMS to your organization. It is unfortunate that some companies perceive their quality systems (mandated by Ford, Daimler-Chrysler, and GM to their suppliers) as an enormous waste of resources and paper with little perceived value. Nothing will automatically protect an EMS from a similar fate.
The bottom line is this: The earlier the critical control points are incorporated into your EMS, the less they will cost to implement and the more short- and long-term value your organization will derive from your EMS.
Many thanks to the EMRs and their companies for allowing me to use examples from their noteworthy EMS: Gary Johnson and Paul Jacobson of Millstone Nuclear Station and Mike Lemon of Pfizer Global Research & Development - Ann Arbor Laboratories (formerly Warner-Lambert Parke-Davis Research). Many thanks also to Phil Stapleton of Glover-Stapleton Associates for the use of his corrective action flow chart.
S. Petie Davis has served as an environmental consultant, manager, and auditor for the past 15 years. She is a Senior Program Manager and Lead Auditor with NSF International Strategic Registrations, a registrar for ISO 14001/9000. NSF International Strategic Registrations is a wholly owned subsidiary of NSF International. Ms. Davis invites reader perspectives and comments on this article. She can be reached at davis@nsf.org or at 734-827-6810.
ISO 14001 Project Reports
NSF International ISO 14001 Project Reports include:
All are available for download (most are free) at www.nsf-isr.org.