The Integration Dr Blog

Organizations that are implementing 3 management systems – Quality (Q), Environmental (E), and Occupational Health and Safety (OHS) – are doing it for a variety of reasons:

• they want to manage all of their requirements under one system;
• they are incorporating, combining, or reducing headcount;
• they are looking for additional savings and efficiencies;
• they are interested in providing information to their employees that are incorporated into one document

What does that one employee document look like?  It may look something like this:

Employees are to manufacture the widget to meet quality and customer specifications (see attached); using safe practice for handling chemicals including applicable PPE (personal protective equipment) – chemical resistant gloves and safety glasses; and if there is any chemical spill, appropriate steps shall be taken including containment and clean-up.

So, we’ve told the employee to make a high quality part (Q), using PPE (OHS), and what to do if there is an accidental environmental impact via spill (E).  The employee shouldn’t look at this and say, “Hey – is this a Q, E, or OHS instruction?”  They should look at it and say, “Hey, this is what I have to do to meet the requirements of my job.”  It should be seamless to them which standard they are meeting; they should meet all requirements, regardless of which standard the requirement originates from.

How to do the integration?  We know from previous posts on integrating Q and E and integrating E and OHS that there are overlapping requirements among the standards.  When implementing the trilogy of standards that are the subject of this post, it is important to remember that, while there are several areas of alignment, including management reviews, internal audits, document and records control, and corrective and preventive actions, there are also several requirements that are unique to one or two of the standards (but not the other(s)).  Therefore, it is important to identify and address the unique requirements, and ensure that they don’t get overlooked in our ecstasy of implementing an integrated system.  What are some of these requirements?  We need to address customer requirements for quality; the environmental aspects/impacts for environmental and health/safety aspects/impacts for OHS; risk management and management of change for OHS; to name a few.

I’d love to hear your comments on your integration – what worked and what didn’t?  Any tips or advice for others?  Please share!

Depending on your industry, you may be asked to integrate an Environmental (E) system with an Occupational Health and Safety (OHS) system to make your system more robust; to save time and effort; or to comply with customer requirements (to name a few of the many reasons cited for integration of E and OHS).

With the latest revisions of ISO 14001 and OHSAS 18001, integration is very easy to implement.  [A joke within the consulting field is that one standard is identical to the other with the exception of the “global replace” – and it’s not too far from wrong].  Since there is virtual identical redundancy in requirements in most cases, integration is the way to get a bigger ‘bang for the buck’.  However, there are important differences between these two standards, and you want to ensure that you are not overlooking the differences between the two standards while doing the implementation.

Unique areas of the standard: for OHS, the organization must consider acceptable risk and risk management; management of change; participation of workers; and incident investigation. For EMS, the focus is on environmental impact rather than impact to workers/safety.

Areas that are similar include a Policy (4.2); hazard (OHS) or Environmental (E) identification (4.3.1); legal and other requirements, and compliance (4.3.2 / 4.5.2); objectives and programs (4.3.3); roles and responsibility (4.4.1); competence, training, and awareness (4.4.2); communication (4.4.3); documentation (4.4.4); control of documents (4.4.5); operational control (4.4.6); emergency preparedness/response (4.4.7); measurement and monitoring (4.5.1);  nonconformity, corrective and preventive actions (4.5.3); control of records(4.5.4); internal audits (4.5.5); and management review (4.6)

You may be considering implementing Quality (Q) and Environmental (E) Systems together from scratch; or you have one of the systems in place, and are considering adding on the other system.  How can you do this?

First, read the previous post about the definition of an integrated system.  For the purposes of this post, we’re going to assume we are looking at a fully integrated system.  Fully integrated systems will have one set of documentation (policy, manual, procedures, etc); one set of records (encompassing all the quality and environmental requirements); one management system review, one integrated audit plan and schedule, etc.

So, what’s our strategy for implementing a Q and E integrated system?

1)     Understand the requirements for both standards

2)     Understand the common elements, that are the most easily integrated (because the working is virtually identical)

1. Policy
2. System Documentation (Manual)
3. Document Control
4. Records Control
5. Management Review
6. Internal Audit
7. Corrective Action
8. Preventive Action

3)     Develop a strategy of how you are going to address areas that do not have a complementary component in the other standard (for example – environmental aspects and impacts in ISO 14001; customer focus and satisfaction in ISO 9001)

4)     Develop a punch list of action items to be addressed, with the goal of implementing the system (Plan The Work)

5)     Place responsibilities (names) and targets for completion (dates) next to the action items.

6)     Implement the plan (Work The Plan), including internal audits to ensure that the implementation is effective and comprehensive.

If an organization chooses to do a partial implementation; you implement step 2, and then skip step 3 before continuing on with the balance of the list.  Partial integration is seen most often in organizations where they have separate existing Q and E functions who do not report to the same management; and where these functions are somewhat entrenched.

One method is not necessarily better than another (partial vs. full integration); it is more often which method is a better fit to the organization’s needs and goals.

Many customers are now requiring that organizations maintain multiple certifications; integrating these requirements into one system eliminates redundancy, the opportunity for error (it says abc in the quality system while the environmental system says def…); and helps employee to understand that it’s not a ‘quality’ requirement or an ‘environmental’ requirement; it’s a ‘process’ requirement or a ‘system’ requirement (in other words, these requirements are cohesive and linked).

Questions on integrating quality and environmental systems?  Contact us at info@mcdcg.com or 512-280-7175 to chat!

Let’s presume that you are working a problem in your facility – the problem is a rather thorny one, and is affecting multiple management standards.  How should you handle the root cause determination, and the corrective action resulting from it?  For reporting purposes, how do you report it for metrics – as a problem in all three metrics?  Do you pick one and let the other standard metrics alone?  What’s the best way to handle this?

Here’s a hypothetical problem:  you’ve noticed that a chemical used in your facility has been used up  prematurely, so there is insufficient quantities to maintain production; you investigate further and discover that an employee was trying to attach a hose without the correct safety equipment and process equipment in place, and he was injured; before he could turn off the valve, the chemical poured out onto the tank farm floor, resulting in a chemical spill.  The resulting problem affects the product quality, employee safety and health, and requires a chemical spill cleanup – so we’ve got an impact from a QMS, OHS, and EMS standpoint.  What’s the best way to handle the root cause determination, and the interim and final corrective action(CA) ?

Our first step is the put an interim CA in place to ’stop the bleeding’.  Our first concern is the employee   – let’s make sure that they’re safe and getting the attention they need.  Ensure that all safety precautions are in place, then institute chemical spill cleanup per your environmental procedures and following manufacturer and MSDS recommendation, paying particular attention to containment and prevention of chemical down drains that lead to water supplies, or out the door and to the soil.  Now that we’ve got the basics covered in the short term, we want to focus on a) understanding why this happened, and b) ensuring that this won’t happen again.  In order to do that ’smartly’, we want to assemble a small team from the major groups affected, to step through a formal corrective action process — determine the root cause — in this case, determine how the spill happened in the first place.  The team should also determine what permanent CA will be implemented, and take steps to put the permanent CA in motion (ordering new supplies, reviewing spill procedures, safety procedures, etc. and determining what will ensure that this problem won’t happen again, for this reason).  Finally, the org should determine what steps need to be taken to prevent this in the future (preventing this from happening for other reasons), and what this impact may have to product quality.  Do customers need to be notified that shipments may be delayed?  Can an expedited shipment of the chemical be ordered and delivered?

Now let’s take a minute to go back and review:

- Quality is affected – shortfall of one of the raw materials

Fix:  investigate expedited delivery

- improper handling resulted in a chemical spill – both environmental and occupational health and safety implications

Fix:  review the existing environmental and safety procedures; update as required;

- Preventive action:  how could a spill have happened if not this way?  How could an employee have been injured if not this way?  How could our product quality have been affected if not this way?

Is there anything we’ve forgotten?  Anything you’d do differently?  Let me know – I’d love to hear your comments!

An EMS is put in place to provide a system for an organization to manage and control their environmental aspects and impacts.

Environmental Management Systems are structured around the following:

- identification of an organization’s significant aspects, and their environmental impacts;

- a policy, supported by plans and objectives, and their targets;

- continual improvement of their environmental performance

- records of environmental performance and achievement of targets

What is ’significant’?  This is sometimes the $64,000 question.  There are many ways that an organization may determine significance — they can identify all aspects/impacts, and rank in order of severity, and work on the top xx%; they can set an objective limit – everything above that limit is considered significant; or any other myriad ways of determining what is significant.  A future post will talk about different tools that are available to make this task less cumbersome…

What the organization should NOT do is to ‘play the game’ with significant aspects/impacts.  One company I visited, which used some pretty nasty chemicals, and was located in an environmentally sensitive area, chose to say that only water – yes, H2O – was significant, since “We use so much more water than we do chemicals”.  OK, that was true – they use tens of thousands of gallons of water – to wash their parts from all these nasty chems, because if an employee was to touch these chems they would receive an immediate chemical burn!  Although I ‘discussed’ with them the severity of the environmental impact results of these chemicals – much more environmentally damaging if spilled than water, as an example – I could not dissuade them from listing water as their only significant environmental aspect.  Needless to say, at the end of the day we mutually agreed to part ways… because I’m not about playing the game; I’m about making a positive environmental impact.

Is an EMS implemented uniformly throughout the world?  Unfortunately, no.  There are many organizations where EMS is a way of life; and the Europeans have been ahead of much of the rest of the world in implementing environmental and sustainable systems.  [I remember traveling to Germany in 1987 and being introduced to paper recycling in the office...]  In other parts of the world, rivers are still treated as a dumping ground for sewage, chemicals, and garbage; and there are little or no environmental controls in place while performing operations including mining, logging, or fishing.

However, the future is not totally bleak – there are more countries supporting implementation of EMSs than ever, and more organizations are implementing EMS and finding the satisfaction of reaping both financial and environmental benefits from it.

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