Buy it off the rack
Experts agree that creating a document control system from scratch to meet
ISO 14001 requirements is not necessary. They suggest taking the document
control system your organization already has in place and adjusting it to
include not only quality and environmental documents but also health and
safety documents.
You don't have a quality management system in place? You had better get
started now, experts caution, because management system integration is not
only essential but inevitable.
There is a strong desire among industry representatives-who author ISO documents-to
integrate elements of ISO 9000 and ISO 14001 once the latter is published
and the marketplace has an opportunity to test it. Already, both technical
committees within ISO are discussing plans to revise both sets of standards
in 1999 so that they will be available to the marketplace by 2005.
The single greatest advantage of having an ISO 9000 system in place first
is that the organization is already familiar with the systems approach and
gets people used to documenting the processes and activities associated
with their jobs, says Joseph Cascio, IBM program director for environmental
health and safety, and chairman of the U.S. Technical Advisory Group to
TC 207.
"A strict document control procedure-such as is required with ISO 9000-provides
the basis for people to replace outdated documents, to track legal mandates
for maintaining documents and to hold on to documents that may be associated
with insurance liability," says Cascio. "Beyond that, ISO 9000
provides a template with an established structure and concept for your company
to use when implementing any management system, not just ISO 14001."
Several companies are saving time and money by combining policy development,
objective and target setting, training and corrective action requirements
into one documentation system that covers ISO 9000, ISO 14001, health and
safety, and other industry-specific programs.
For example, Texas Instruments is implementing ISO 14001 and is including
documentation for health, safety and Department of Defense requirements
in a single manual. However, only the EMS documents will be audited by a
third party. The other documents are for internal use.
Akzo Nobel Chemicals Ltd., a BS 7750-certified company in the United Kingdom,
combined quality and environmental manuals into one document. New procedures
have been written, but most changes have been written into existing procedures.
BS 7750 is the United Kingdom's EMS standard and formed the foundation for
ISO 14001.
Millar Western Pulp Ltd. in Alberta, Canada, the first BS 7750-certified
company in North America, added EMS-oriented amendments to its quality system
document control procedures and referred readers to job responsibilities,
authorities and training in the main quality management system manual. The
company cross-references these requirements in the EMS manual and simply
directs auditors to the QMS manual.
Frontload to avoid deadline headaches
To develop an effective ISO 14001 documentation system, you must work intensely
in the beginning and simply tie up loose ends at the end, suggests Marie
Godfrey, a management consultant specializing in developing management system
documentation with Franklin Quest Consulting Group. This technique is known
as "frontloading." People typically construct documents ineffectively
by starting slowly and building to a frenzy before and often after the deadline,
says Godfrey.
Frontloading includes planning the project, determining the format for all
related documents, prototyping each document and scheduling writing and
reviews. If you frontload effectively, says Godfrey, the people who know
the content will be the ones who plan and structure the documents. Then,
those comfortable with writing do the word processing, editing and proofreading.
The following four action elements to help companies perform an initial
assessment of their current system were developed by John Earnhardt, an
auditor with SGS International Certification Services:
· Become informed on emerging standards by reviewing recent drafts of the
ISO 14001 guidance and specification standards.
· Assess the value of an EMS and ISO 14001 certification for your business.
· Perform an EMS review or gap analysis of where your company is and where
it would need to be to implement and integrate the standards.
· Use the information to prepare a strategy for addressing and implementing
ISO 14001.
Once this assessment is complete, the quality manager and the environmental
manager should get together and discuss implementation and document development
strategy, suggests Earnhardt. During this time, you should ask yourself
if the current documents meet the needs of their audiences.
Documents not used might as well not exist, recommends Godfrey. She suggests
you answer the following questions before proceeding any further:
Do the documents have:
· Purpose statements?
· Clear and logical organization?
· Content required for the job to be done as well as for meeting the requirements
in the ISO standard being applied?
· Information presented in the most appropriate form (visually whenever
possible)?
· Messages and supporting information conveyed through good writing techniques?
Documentation should be useful, usable and understandable, stresses Ian
Durand, president of Service Process Consulting. EMS documentation should
be written between an eighth- and 12th-grade reading level so that all employees
can understand the documents, he advises.
Fill in the holes
Once you know what you need, you can develop a plan and schedule to create
the missing documentation, says Godfrey. She suggests that your plan include
the following elements:
· An environmental system manual that outlines the environmentally related
policies and that addresses Section 4.1-Environmental Policy of ISO 14001.
· Procedures that identify all company processes and products that might
affect the environment and that identify relationships of personnel, departments
and processes.
· Work instructions that specify directions for a particular task (e.g.,
how to assess the effect of machine A on airborne emissions).
· Reporting forms that are templates to be filled in with data (e.g., incident
reports, process information, training records).
· Large sheets of paper to construct a work-in-progress wall chart. This
chart should be filled in as follows:
· List all documents needed. Group the documents in logical sets, according
to production lines, etc.
· For each document, identify the people who will read and use it.
Everyone must know and understand the contents of the EMS, but only a few
people such as specific workers and supervisors are responsible for a single
set of work instructions.
· Set a prototype date for each document.
· Leave space for writing deadlines and review dates.
· Identify the date of the next internal EMS audit.
· Use your company's internal communications system (e.g., newsletters,
bulletin boards) to tell all employees what is happening and obtain their
input.
"This is everyone's opportunity to run the company," says Godfrey.
"Don't forget to include external communication such as stockholders
and the nearby community."
Make technology work for you
The term "documentation" immediately conjures up images of burdensome
corporate recordkeeping. But with advances in technology, electronic documentation
is gaining popularity. However, it is too early to predict whether electronic
documentation will displace paper because many companies and auditors say
that both are important.
Durand prefers a hybrid system. "People who are used to a local area
network will definitely go for electronic documentation, while paper has
the advantage of easy access," he says.
On the other hand, some auditors say that paper documents may be examined
more carefully. The main advantage of paper is that most people find it
easier to read, but electronic documentation is usually easier to control
and change, says David Hadlet, director of business development at Lloyd's
Register Quality Assurance Ltd., which certifies companies to BS 7750,
ISO 9000 and ISO 14001. The search engines built into many electronic documentation
systems can provide an advantage, but when it comes to finding information
about cost, either medium can have the advantage, depending upon the purpose
of the search.
"The perfect management system-which, of course doesn't exist-will
probably have a mix of both electronic and paper," states Hadlet.
Because companies are unique, you should design a documentation program
that makes sense for your company, says Dawne Schomer, corporate environmental
health and safety audit program manager at Texas Instruments.
EMS documentation is a natural outcome of a company's progression from a
"firefightin" approach to environment, health and safety requirements,
to having consistency among these programs, and to expecting continuous
improvement and system excellence, says Schomer. Documentation requirements
would only become a problem if documentation were viewed as an exercise
without value or meaning.
"The hardest documentation task is the generation, issuing and reissuing
of large quantities of procedures, which can be arduous and labor-intensive,
especially in a large company," says Michael McBride, customer services
manager for Smurfit Paper Mills in Ireland.
This disadvantage is being overcome gradually through the use of networked
PCs. The document is fed into a master computer that is linked to other
PCs, explains McBride. Any obsolete procedures are superseded or removed
from the master computer, which eliminates the need for photocopying and
circulating up-to-date documents frequently and by hand.
Involve end-users in prototyping
Before choosing between paper or electronic formats for documents that you
prototype, begin by visualizing the end results you expect. Using a prototype
is the most effective way to frontload the documentation process, advises
Godfrey. She stresses that the best people to draw up document prototypes
are the people who will use them.
The best way to develop prototypes, advises Godfrey, is to answer the following
questions:
· What is the purpose of the document?
· Who will use it and how will they use it?
· Will some other size be more convenient than 8.5" x 11"?
· How long should the document be?
· What must be included in the document? Which information is most critical?
· What is the best arrangement of the information? Will the user read sequentially
or randomly?
Using Post-it notes, large sheets of paper or any other convenient format,
construct the document one page at a time, suggests Godfrey. At first, you
simply place each main topic on a page. The pages will look quite empty,
and you may be tempted to put more than one topic on each page.
Allot pages according to the importance of the topic, and be sure to plan
for a table of contents, index, glossary, etc. This initial prototype should
take two to four hours to create. By the time you finish, everyone should
understand what the final document will look like and what it will contain.
"Flesh out the details of the pages by creating an interim prototype,"
advises Godfrey. Determine whether to use drawings, flow diagrams or other
aids to help the user. Add headings and subheadings to create mock-up pages
of the final document. But do not simply add pages as sections of text grow;
pare the proposed information to its essential elements.
Flowcharts can be very effective in any management system documentation,
including ISO 9000 and ISO 14001, says Hadlet. However, he warns you to
recognize that flowcharts by themselves are rarely sufficient to convey
information in the level of detail necessary to assure the appropriate consistency
of operation. Include supporting instructions and/or evidence of "suitable
training" to supplement the flowcharts, suggests Hadlet.
After developing the structure and presentation format of the documentation
system, the time has come to write the documents. Assign writing tasks based
on the person's knowledge and interest in the subject, suggests Godfrey.
Then schedule a review of the interim prototype in a week or two. Displaying
a prototype on a wall where writers can constantly refer to it will encourage
them to tack suggestion notes to the documents.
By reviewing the documents as they are being developed, you can monitor
the direction of the documents and point out obvious overlaps between quality
and environment, which will help prevent duplication, according to experts.
Integration may not be for you
Integration is not for everyone because it depends largely on the maturity
of the current systems in place. According to several experts, if your system
is not very mature, you may find the advantages that come from a reduction
in paperwork and time may not outweigh the need for more extensive coordination
efforts between your quality management system and your EMS. If you did
not take environmental, health and safety into account when developing your
quality system, then integration may be a distant goal.
Having an ISO 9000 system in place eliminates the need for people to undergo
a "mental paradigm shift" when preparing documents for ISO 14001",
says Richard Paduska, director of health, safety and environmental affairs
for Eastman Kodak Co. By using the rigid ISO 9000 philosophy-"do what
you say and document what you do" -people are already regimented in
developing process-oriented documents, he says.
But Paduska describes ISO 9000 as a horizontal system that stipulates that
you manufacture a product to the quality agreed to by yourself and the customer.
This is a continuous production process that produces a consistent product,
he says. However, ISO 14001 is a horizontal system that ties every aspect
of the system back into the EMS policy and is anchored by the concept of
continuous improvement. ISO 9000 does not need senior-level support the
way ISO 14001 does, Paduska claims. He adds that not only does ISO 14001
need it, but it will not work without it.
"Conceptually, there are many similarities between an ISO 9000 and
ISO 14001 system, but realistically you may never be able to combine documentation
for the two systems into one coherent management system manual," predicts
Paduska. "It would be difficult for any auditor [internal or external]
to pick apart pieces of the manual depending on the system being audited,
e.g., quality, environment, health and safety, finance, resource allocation."
Kodak is considering integrating ISO 14001 with ISO 9000 in some of its
European facilities but has not even considered integration for its U.S.
facilities, according to Paduska. Internal audits in Europe will help Kodak
flesh out the similarities between the two standards, he says.
The SGS-Thomson Microelectronics facility in Rancho Bernardo, California,
recently became the first U.S. facility to achieve certification to both
ISO 14001 and the European Union's Eco-Management and Auditing Scheme. While
the plant is ISO 9001-certified, it did not leverage its ISO 9001 system
heavily.
Documentation for the two systems is maintained in separate manuals but
should be integrated by 2000, says Patrick Hoy, the site environmental manager.
ISO 9000 provided a base but was not essential to implementing ISO 14001,
explains Hoy. SGS-Thomson has mandated that all its facilities around the
world implement and register to EMAS, but Hoy says not all facilities are
ISO 9000-certified.
Dupont de Nemours Co.'s Safety, Health and Environmental Excellence Center
will use ISO 9000 wherever possible to implement ISO 14001, says Barbara
McGuinness, manager of environmental audit programs. However, ISO 9000-unlike
ISO 14001-is not a corporate system and therefore no documentation exists
at the corporate level. Without the use of ISO 9000 at this level, it will
be difficult to identify where the two systems overlap.
"I am sure there are various overlaps associated with ISO 9000 certification,"
says McGuinness. "However, each of the 45 business units will determine
where those overlaps fit into their existing systems."
About the authors . . .
Caroline G. Hemenway is publisher of CEEM Information Services in
Fairfax, Virginia. Gregory J. Hale is associate editor of "International
Environmental Systems Update," a monthly newsletter on ISO 14000 developments
and implications. CEEM publishes "IESU" and several other ISO
14000 and other management systems products.
For more information, contact CEEM at (800) 745-5565 or (703) 250-5900;
fax (703)