Qudos Management Pty. Ltd. Quality | OHS | Environmental management solutions 320 Adelaide Street, Brisbane, QLD 4000 GPO Box 111, Brisbane, QLD 4001, Australia Tel: +61 7 3010 9259 | Fax: +61 7 3010 9001 Email: [email protected] Web: www.qudos-software.com www.qudosclub.com How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Article by Alan M. Jones BA – Lead Auditor, Management consultant with Qudos Management Pty. Ltd. and co-author of the Enviro Manager Guide Book. Introduction Throughout the world, it‟s clear that there are growing concerns about climate change, sustainability, and other environmental issues. The wider community is paying increasing attention to how business activities impact on the environment. In fact, some customers are now specifying environmental management requirements for their suppliers to meet. Perhaps the most tangible evidence of an organisation's environmental commitment is to have a management system certified to the ISO 14001 standard. Over 8,000 organisations in Australia / New Zealand alone have already achieved that distinction, yet more than 5 times that number have management systems certified to the ISO 9001 Quality standard. Many thousands more have substantial management systems in place but haven‟t yet sought certification. For them, a logical progression might be to expand their existing QMS (Quality Management System) into an IMS (Integrated Management System) that also meets the requirements of ISO 14001. This article takes a brief look at the issues involved in doing just that. Before we move on, let‟s just clarify what the ISO 9000 and ISO 14000 series or family of standards are about. The following is a brief extract from the official ISO web site: The ISO 9000 family addresses "Quality management". This means what the organization does to fulfil:     The customer's quality requirements, and Applicable regulatory requirements, while aiming to Enhance customer satisfaction, and Achieve continual improvement of its performance in pursuit of these objectives. The ISO 14000 family addresses "Environmental management". This means what the organization does to:   Minimize harmful effects on the environment caused by its activities, and to Achieve continual improvement of its environmental performance. How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 1 of 6 Copyright © 2010 Qudos Management Pty. Ltd. The good news You know those conversations where you‟re asked “Do you want the good news or the bad news?” Well, in this case, there isn‟t really any bad news – just some extra activities and controls that need to be put in place. We‟ll get to those in a moment, but the really good news is... If you have a QMS that complies with ISO 9001, you ALREADY comply with most of ISO 14001. The reason is that many of the requirements are very similar. It‟s mostly a question of focus - on product/service quality OR the environment. What are the similarities and differences? Similarities Both standards are based on the methodology of the PDCA (Plan-Do-Check-Act) cycle, and both have aims of achieving continuous improvement. The following table – while not exhaustive – gives some indication of management system activities based on the PDCA cycle, and how the 2 standards have at least broadly similar requirements for them. Subject summary ISO 14001 Environment ISO 9001 Quality Set out the overall policy Set measurable objectives 4.2 Environmental policy 4.3.3 Objectives, targets and programme(s) 4.4.1 Resources, roles, responsibility and authority 5.3 Quality policy 5.4.1 Quality objectives Allocate responsibilities / authorities Ensure that people are trained, competent, and aware of their role Document the system 4.4.2 Competence, training and awareness Manage those documents Manage activities Deal with exceptions 4.4.5 Control of documents 4.4.6 Operational control 4.5.3 Nonconformity, corrective action and preventive action 4.5.4 Control of records 4.5.5 Internal audit 4.6 Management review Records management Planned audits of the system Management review of the system 4.4.4 Documentation 5.5.1 Responsibility and authority / 5.5.2 Management representative 6.2.2 Competence, training and awareness 4.2 Documentation requirements 4.2.3 Control of documents 7 Product realization 8.3 Control of nonconforming product / 8.5 Improvement 4.2.4 Control of records 8.2.2 Internal audit 5.6 Management review Differences Well, apart from their focus being on different compliance issues, there are also some practical differences between the requirements of the 2 standards. These include: ISO 9001 tends to be more prescriptive in requirements for documentation For example, there are requirements for you to have a „Quality manual‟ and documented procedures for at least 6 clauses:  Control of documents How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 2 of 6 Copyright © 2010 Qudos Management Pty. Ltd.      Control of records Internal audits Control of nonconforming product Corrective action Preventive action While ISO 14001 DOES have similar clauses, and DOES require there to be procedures to manage those activities, those procedures DO NOT generally have to be documented. However, if you have already documented them for the purpose of compliance with ISO 9001, there is no reason why those existing documented procedures cannot also apply to your equivalent environmental management activities. They just need to be reviewed and adjusted to suit both purposes. ISO 14001 does not have an equivalent documentation requirement to the „Quality manual‟. However, if you already have one, it could be expanded to include relevant information such as the environmental policy, information on environmental responsibilities and authorities, and a table indicating how the various ISO 14001 clauses are addressed. In cases where this is done, it is quite typical to rename the document from „Quality manual‟ to „Business manual‟ or „Compliance manual‟. Consideration of environmental aspects and impacts For those that have only previously had exposure to quality management, one of the key differences in ISO 14001 will be found in Clause 4.3.1 ENVIRONMENTAL ASPECTS. Certain aspects of an organisation's activities, products or services will have some impact on the environment. For your organisation, you should identify what those aspects are, what impacts they have, and assess their significance. This might be considered a risk assessment activity. You then need to put controls in place to manage those that are considered to be significant. At this point, it might be helpful to offer a definition of the terms 'environmental aspect' and 'environmental impact':  Environmental aspect An element of an activity, product or service that has an impact on the environment  Environmental impact A change made to the environment as a result of an environmental aspect You might think of them simply in terms of Cause and Effect. Let's take a look at some examples of environmental aspects:  Consumption of cardboard for packaging products  Consumption of fuel for delivery vehicles  Use of energy for office lighting The following are examples of environmental impacts:      Noise nuisance to local community Depletion of non-renewable energy resource Water pollution Air pollution Increased carbon dioxide levels in atmosphere To address this element of the standard, you need an initial environmental review to identify your aspects and impacts, assess their significance, and plan a hierarchy of controls to appropriately manage them. External communications How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 3 of 6 Copyright © 2010 Qudos Management Pty. Ltd. While both standards require organisations to establish methods of internal communications about the management system, ISO 14001 also requires procedures for handling communications with external interested parties such as customers, regulators, and the wider community. What are the key challenges? We asked some representatives of certification bodies: What do you consider to be the number 1 challenge for an organisation going from a QMS to an IMS incorporating ISO 14001 requirements? In the view of Scott Walker, Queensland Operations Support Manager for SAI Global; “The greatest challenge for a QMS moving to an IMS incorporating ISO14001 requirements is the shift in focus from product risks to those associated with the environment and human health, and from consumer protection to environmental protection”. Garry Allan, Senior Environmental Auditor also with SAI Global comments “Many IMS have trouble focusing appropriately on the specific requirements of each area”. Ian White, Senior Quality and Environmental Auditor with Sci-Qual suggests; “An Organisation must define the EMS framework in relation to both the system requirements of the 14001 standard and the significant environmental aspects linked to their operational activities. Ideally the Organisation will perform an environmental audit of their operations to determine the environmental aspects associated with their operations. From a perspective of commercial viability, the Company must then risk-assess their significant environmental aspects to minimise the potential and/or real significant environmental impacts that may/do occur as a result of their operational activities. The number one challenge in the integration of the EMS and QMS into a functioning IMS is the inclusion of those significant environmental aspects, there impacts and controls into the operational procedures of the organisation”. So how do you go from a QMS to an IMS incorporating ISO 14001 requirements? The first step should be to perform a gap analysis. Gap analysis A gap analysis is a study to compare a current situation with a desired situation. There are two key questions:   Where are we now? Where do we want to be? To answer those questions in the context of environmental management, a table should be prepared that lists the ISO 14001 requirements (or at least a summary or interpretation of them). The ISO 14001 standard may be obtained from your local standards association and other approved sources. For each requirement, you may then note current arrangements (if any) that are in place, and the gaps between them and what is needed for compliance to the standard. The gap analysis may be performed in-house or by a consultant. The Qudos Enviro Manager toolkit includes a gap analysis tool to assist with this exercise. How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 4 of 6 Copyright © 2010 Qudos Management Pty. Ltd. The choice of which path to take will be determined by several factors – including the availability of inhouse expertise, the complexity of the business, and its environmental aspects/impacts. However it is performed, the gap analysis provides the foundation stone on which to plan and develop the wider IMS. As mentioned above, you will also need to perform an initial „environmental review‟. Certification Many certification bodies that audit and certify to ISO 9001 will perform the same service for ISO 14001. The cost of certifying an integrated management system that addresses both standards should also be less than the simply doubling the price of a single certification. There may be reductions in administration costs and audit time for combined audits. To some degree, this may depend on the extent to which your systems are integrated. EA (The European Co-operation for Accreditation) has produced EA-7/05 - a document that provides guidance on combined certification audits. This document has also been adopted by JAS-ANZ - the government-appointed accreditation body for Australia and New Zealand. While primarily aimed at certification bodies themselves, EA7/05 may provide some useful background information for individual organisations seeking to extend their management systems. The document may be found at: http://www.european-accreditation.org/n1/doc/EA-7-05.pdf How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 5 of 6 Copyright © 2010 Qudos Management Pty. Ltd. Contact your certification body to discuss your combined certification options. Conclusion Concern about the environment is only likely to increase still further. As stated in the introduction, having a management system certified to the ISO 14001 standard is perhaps the most tangible evidence of an organisation's environmental commitment. As can be seen from the above, for those with an existing ISO 9001 QMS, the step to an IMS that also complies with ISO 14001 may be smaller than might be imagined. It‟s certainly worth considering on many levels. Much of the necessary work can usually be done in-house. That work may be assisted by consultancy services, training and software to provide guidance, save time and reduce ongoing administration effort. References: www.iso.ch www.european-accreditation.org Acknowledgments: Many thanks for input to: Scott Walker and Garry Allan of SAI Global, Ben White and Ian White of SciQual International, and Steve Keeling of JAS-ANZ. How to extend your existing QMS into an IMS addressing ISO 14001 Environmental requirements Page 6 of 6 Copyright © 2010 Qudos Management Pty. Ltd.