As quality professionals, you know that U.S. industry was practically blindsided by the European use and preference for ISO 9000 quality management system standards in the late 1980s and early 1990s. Those same companies are beginning to face the reality that the new ISO 14000 standards on environmental management are not going to disappear from the radar screen anytime soon.
While the ISO 14001 environmental management system specification standard was published in September 1996, organizations worldwide have been preparing to implement an EMS that conforms to the requirements of ISO 14001 since mid-1994. Similar in structure to ISO 9000, ISO 14000 is based on the popular Deming model of management, with the key ingredients being plan-do-check-act. Companies worldwide are taking this time-proven methodology and applying it to other aspects of their operations -- everything from research and design to finance and resource allocation.
How will your organization, which is probably stretched to the limit on resources and patience, deal with these new standards and the challenges associated with implementation? How will organizations like yours juggle these standards and associated environmental approaches when you haven't even mastered the multitude of processes and procedures associated with your ISO 9000 system? And how will you ever find the time to manage both quality management and environmental management in a 24-hour day?
To succeed in integrating systems, you must concentrate and build on what already exists, as opposed to developing large manuals and operating procedures for each management system element. Be careful not to fall into the trap of developing separate and distinct procedures for each function with no links to other facets of the management system.
There's no magic bullet for this complicated and potentially expensive dilemma, but you can learn from people and organizations that are integrating ISO 14000 into other operational aspects of the organization, including health, safety and quality. ISO 14001 implementation need not be costly or present unrealistic expectations. By using the quality management system, you have in place a blueprint to build the requirements of ISO 14000, health and safety, and other management practices into the fabric of the organization in a manner that won't break the bank.
Since the early 1970s, companies have considered environmental auditing an exercise to ensure that their facilities are in legal compliance with local, state and federal environmental laws. Typically, these audits cover everything going out of the facility, from air and water discharges to hazardous and radioactive wastes. A management system approach asks auditors to consider these elements as potential impact areas. By combining the legal or performance aspects of environmental stewardship with the management system, experts hope that companies will reach a new level of environmental performance.
These experts also advocate taking this approach beyond quality and environment to other aspects of the organization, such as design, occupational health and safety, and risk management. They argue that the same concepts and principles apply to any management system, and with a reliable auditing program, an organization can reap untold benefits and savings.
Akzo Nobel integrates
In 1996, chemical manufacturer Akzo Nobel committed several U.S. sites to joint registrations for ISO 9000 and ISO 14001 in an effort to eliminate the redundancy associated with distinct audit teams and schedules. The company's LeMoyne plant in Axis, Alabama, became certified to the final draft of ISO 14001 in June 1996 and received its ISO 9002 surveillance certificate at the same time.
"When we were implementing ISO 9002 and studying ISO 14001, we couldn't help but notice many similarities between the two standards," says Kay Higby, responsible care superintendent for Akzo Nobel. "It was a natural progression to go from having separate systems to an integrated one."
Paul Kaminski, the Under Secretary of Defense for Acquisition and Technology, agrees: "We are committed to preventing pollution; to being innovative in the way we utilize technologies; to complying with all federal laws and regulations; to conserving natural and cultural resources; to cleaning up toxic waste; to being a good partner with our communities; and, therefore, being a leader in terms of environment, health and safety issues on into the future."
Prior to ISO 14001, the company had a sound operating policy but needed to craft certain language to satisfy requirements for both ISO 9000 and ISO 14001. For example, the company drafted a brief statement on its commitment to the prevention of pollution to satisfy requirements contained in both ISO 14001 and the Chemical Manufacturers Association's Responsible Care program. Higby notes three benefits of joint audits:
Lower costs
associated with having the team travel to the facility only once.
Easier
preparation for employees who only had to prepare for one audit.
More
efficient use of internal audits to prepare for third-party
assessments.
Integration saves
Multiple avenues exist for organizations to save thousands of dollars and precious time by integrating ISO 14000 into current management systems rather than trying to develop new documents and processes, suggests James Highlands, president of the management consulting firm Management Systems Analysis Inc. in Royersford, Pennsylvania. Organizations don't need to develop a separate document control system for environmental management because most of the procedures and policies can be developed using the same templates available for ISO 9000.
In fact, procedure writing and policy development is a generic exercise that can be used for any management system element. Record-keeping activities are also "stock" activities that don't need to be separated or redeveloped for ISO 14000. For example, operational records that describe the organization's training process can be used as the basis for environmental management records describing environmental aspects and potential impacts associated with training activities.
"Developing efficient training tools and programs for environmental management does not have to be difficult, because in the process of implementing your quality management system, you have already identified training needs," explains Highlands. "Now it's just a matter of expanding the subject matter of those tools and programs to cover related management system areas."
A key element of any management system is the process for handling and documenting corrective actions associated with system nonconformances. This is where you will get the most mileage out of your auditing procedures and policies established under your quality management system. As with ISO 9000, the corrective action system developed under your quality management system can serve as the basis for your corrective action system for any area of the management system.
"It requires very little effort to take the corrective action plan in place for quality and expand it to cover manufacturing, process engineering, environment and health and safety," notes Highlands. "You want to develop a procedure that allows your generic management system to find a discrepancy, evaluate the issue and address nonconformances in every aspect of the management system."
Document control integration
In order to implement an environmental management system, organizations must prepare several layers of documentation, remarks Marcos Antonio Lima de Oliveira, quality nuclear coordinator for the Brazilian petroleum company CETEAD. Documentation structure for any management system is similar to quality systems implemented according to ISO 9000. This structure is composed of an environmental management manual, procedures, operational instructions and records. In order to manage such documents, organizations must implement specific document controls.
"If you expect to instill confidence in the company's senior management -- as well as independent stakeholders -- on management system performance, it is critical to have an audit system in which independent auditors (internal or external) are used," advises Oliveira.
An audit compares current practices against approved standards or procedures. So, to have a good audit system, you must have adequate documentation. There is a big similarity between quality and environmental auditing in the planning, selection of auditors, reporting, corrective action, procedures, etc. These practices can also be modified to address other important management system elements.
While data relates to facts, information refers to a series of data analyzed to provide a decision. Information is an answer to a question and a tool for decision making. The quality of information depends on its relevancy, precision and speed. Information must be continuously reanalyzed and renewed. It becomes volatile if it is not registered, indexed and updated. Internal and external auditors will use this information to judge whether you are in conformance with your established management system policies and procedures.
"Usually, executives who make decisions receive an exaggerated quantity of data but rarely get the information they need presented clearly and adequately for using in decisions," explains Oliveira. "Decisions are usually related to solving problems, and to solve a problem, we need information. Any management system requires a documentation system in order to collect, analyze, register and retrieve information."
Ford Motor Co. is launching an international campaign to have about 150 of its manufacturing facilities certified to ISO 14001 by the end of 1998, according to Graham Chatburn, EMS manager in the Ford environmental quality division. Integrating ISO 14001 elements into the company's comprehensive quality management system will be the key to the company's proposed time line. Ford is combining proven ISO 9000 procedures with developing ISO 14001 auditing procedures for design, manufacture and disposal of materials.
"We don't see the need to develop new internal auditing protocols for our ISO 14001 environmental management system when the protocols established under our ISO 9000 system will cover the majority of the elements under ISO 14001," stresses Chatburn. "For example, the ISO 9000 policy, training, document control and management review processes are identical and readily adaptable to any management system. However, we had to develop new protocols and procedures for assessing how our existing environmental compliance system could be expanded to include management system elements such as voluntary requirements and obligations."
Throughout 1997, Ford will be training auditing teams made up of quality management professionals and environmental compliance auditors to conduct internal audits for ISO 14001. Ford's environmental management system also includes elements of health and safety, but they are beyond the scope of the EMS standard and will not be part of the EMS registration audit.
Mexican integration approach
Victor Cintron, a principle in the management system consulting firm Bulltek International, is working with Pinturas DOAL, a protective coatings producer of metal, plastic and wood in Mexico, on implementing a comprehensive dual management system for quality and environment. While the ultimate target was ISO 14001 certification, the company is pursuing management system integration with Bulltek using a unique philosophy called Kaizen-Blitz. The philosophy combines kaizen -- the continuous improvement of the organization's operating systems in response to audits, market pressures, suppliers, employees and others -- and blitz, which characterizes the organization's leadership and operating core searching for timely business opportunities.
"DOAL has managed to more than double its sales within a time window typically more in tune with Mexico's other two NAFTA partner-countries," declares Cintron. Human development and training is one of the practices -- along with numerous others such as sales and marketing -- that is jointly re-evaluated and acted upon on an ongoing basis.
Ultimately, the robustness of DOAL's operating system is strengthened by the implementation of ISO 14001, the kaizen element. Progressive growth in DOAL means, among other things, continuous consistency in their formulated batches, reduced time-to-market, teamwork, knowing their customers and users, an eagerness to continuously learn about their market, the courage to take risks, continuous development, placing their product at a competitive cost and continuously building better relationships with their suppliers.
QS-9000 integration
SSI Technologies, a medium-sized anti-lock brake sensor manufacturer, will be using the U.S. auto industry's QS-9000 quality system as the umbrella management system for other management system elements, such as environment and health and safety. The Janesville, Wisconsin, company controls roughly 30 percent of the anti-brake sensor market in North America, with many SSI customers supplying directly to Ford, Chrysler and General Motors, according to Douglas Wall, SSI's corporate environmental manager. The company first approached integration of health and safety into the existing QS-9000 system in 1995 but determined that an environmental management system such as ISO 14001 would be a better fit. The company has not determined whether it will seek registration to ISO 14001 or wait and watch the auto industry for contract-procurement preferences.
"Where QS-9000 looks for a quality standard, health and safety, and environmental issues are more closely tied by regulation and therefore the logical choice for an integration mechanism," explains Wall.
For example, there are noticeable overlaps between regulations enforced by the Environmental Protection Agency and the Occupational Safety and Health Administration. OSHA's worker "right to know" act and its relationship to the EPA's Superfund initiative are perfect initiatives to combine into the same training program. "It would not make business sense to conduct different training exercises for the EPA's material safety data sheets and OSHA's 'right to know' regulations," insists Wall.
He is combining the company's audit program under one comprehensive management system for evaluating training, effectiveness monitoring, corrective and preventive action, management reviews and continuous improvement procedures. While each audit program element will use the same "conveyance" tools and training personnel, each management system element -- quality, environment, health and safety -- requires a separate audit.
"Each of our departments will audit the others to ensure that no department is assessing its own systems," notes Wall. "We would eventually prefer to have one comprehensive management system that uses the same manual, procedures and policies, but those decisions are based on cost, quality and delivery. Therefore, when the time comes, it will make sense to use our ISO 9000/QS-9000 system as the basic structure for total integration of our systems."
Companies should maintain the integrity of separate management systems, emphasizes Joseph Cascio, chairman of the U.S. Technical Advisory Group developing the ISO 14000 series of standards and vice president of EMS for the Global Environment & Technology Foundation. Formerly an executive in IBM's environment, health and safety department, Cascio comments that "integrating systems for quality, environmental and health and safety makes sense and avoids unnecessary costs." The challenge is to resist the temptation to cut corners that jeopardize the efficiency or credibility of the system or organization.
About the author
Gregory Hale is the ISO 14000 information specialist for the ISO 14000 Integrated Solutions (IIS™) program, which is a joint venture project between the American National Standards Institute and the Global Environment & Technology Foundation. His primary responsibility is the design and management of the IIS On-Line™ Web site (http://www.iso14000. org), which includes news articles, case studies, chat rooms with EMS experts and an online purchasing presence.
For more information, contact ISO 14000 Integrated Solutions, 7010 Little River Turnpike, Suite 300, Annandale, VA 22003. Telephone (703) 750-6401, fax (703) 750-5438.
