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!

Occupational Health and Safety has long been legislated in many parts of the world.  In other areas, OHS control is virtually non-existent, and the impact in these areas (Africa, China, etc. come to mind) is significant.

Let’s talk first about what OHS is, then we can dive into why this standard varies so widely across the globe.

In developed countries, OHSMS is probably in place because it is also mandated / regulated by law.  These countries have had  laws in place much longer than the OHS standard 18001 has been in existence; so complying with OHSAS 18001 has not been difficult.  However, there is little impetus for companies to implement OHSAS 18001:2007 compared with other standards in these countries, since they are often not implementing significant new processes (and therefore reaping significant new benefits).

In developing countries, OHS systems may not be the norm; nor are these countries emphasizing OHS legislatively.  At a recent NOSHCON conference, several speakers presented data on the impact of poor nutrition, dehydration, and substandard working conditions on the accident/incident rate in South Africa.  Not surprisingly, the more compromised a worker is due to ill health (25% of the population is HIV compromised), poor nutrition (employees in the field are fed ‘pap’ – something akin to grits – with hot sauce as their meal); or dehydration (water stations are spaced too far apart to allow workers to get a drink, despite the heat and humidity, without loss of productivity; so workers who are paid by the piece do not hydrate except at lunch, which leads to chronic dehydration).

What is a OHSMS?

it has very similar elements to the QMS and EMS system we’ve discussed in previous blog posts – and this is by design.  Therefore, it has a policy, supported by planning, objectives, and targets; it asks the organization to identify health and safety significant aspects and impacts; and it monitors OHS performance, and provides for continual improvement of that performance.

What are the benefits of a OHSMS?

- it allows the organization to perform a formal assessment of their system.  This is one of the indicators that every company has mentioned in their exit survey as a key benefit.

- it provides the organization with a framework to implement OHSMS as described above.  This gap analysis road map provides a clear action item list, to provide continual improvement project sources.