What do we do when we find a problem?
Fixing EMS problems and avoiding them in the future
Nonconformance means...
• system does not meet the EMS criteria (such as ISO 14001)
-or-
• implementation is not consistent with the EMS description
Recurring problems are expensive !
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No EMS is perfect. You will probably find problems with your system, especially in the beginning (through audits, measurement, or other activities). Your EMS will also need to change as your organization changes and grows. When
system deficiencies are encountered, your organization will
need a process to ensure that:
• problems (including nonconformities) are investigated; • root causes are identified;
• corrective actions are identified and implemented; and, • corrective actions are tracked and documented.
EMS nonconformities and other system deficiencies should be analyzed to detect patterns or trends. Identifying these trends will allow you to anticipate and prevent future problems.
Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur (or after they reoccur). This approach is consistent with the continual improvement philosophy.
Management Review Corrective Action System Audits = System Improvement Hints:
• If your organization has an ISO 9000 management system, you should already have a corrective / preventive action process for quality purposes. You can use this as a model (or integrate with it) for EMS purposes.
• Small companies might find they can combine their management review and corrective action processes, especially if the same people are involved in both. At the very least, a strong link should exist between the two processes.
• The amount of planning and documentation needed for corrective / preventive actions can vary with the severity of the problem (and its potential environmental impacts). Don’t go overboard with bureaucracy — simple methods
Why do EMS problems occur?
Typical causes include: • poor communication • faulty or missing
procedures
• equipment malfunction (or lack of maintenance) • lack of training
• lack of understanding (of requirements)
• failure to enforce rules
Key Steps:
• identify the problem
• identify the cause (investigate)
• come up with solution • implement solution • document solution • communicate solution
People doing the work are often in the best position to see
problems and suggest solutions.
The Tool Kit contains a sample corrective action procedure and tracking log
(see page 139).
• Once you document a problem, the organization must be committed to resolving it. Corrective actions should be implemented as quickly as possible. Be sure that your corrective / preventive action process specifies
responsibilities and schedules. Review your progress
regularly and follow up on any deficiencies.
• Make sure you collect the right data / information to make good decisions. While many corrective actions may be “common sense,” you need to look below the surface to determine why a problem has occurred.
• Initially, most EMS problems may be identified by your auditors. However, over the long run, most problems and good ideas may come from the people in the shop doing the work. This should be encouraged. Find ways to get employees involved in the system improvement process (for example, via suggestion boxes, contests and incentive programs).
Audits Monitoring Other
Sources Employee Suggestions Sources of change Corrective Action Process Management Review Investigate and recommend solutions Institutionalize Change Review: Have we …
developed procedures for investigating, correcting, and preventing system deficiencies?
set up a process for assigning responsibilities for and tracking completion of corrective actions? set up a process to revise procedures or other EMS documents based on corrective / preventive actions?
Records
How do we prove that our EMS is working?
Evidence that the EMS is working properly
Records should be important to the operation of the EMS, including your regulatory compliance efforts.
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Key Questions:
• what records are kept? • who keeps them? • where are they kept? • how are they kept? • how long are they kept? • how are they accessed? • how are they disposed?
The value of records management is fairly simple — you should be able to prove that your organization is actually implementing the EMS as designed. While records have value internally, over time you may need to provide evidence of EMS implementation to external parties (such as customers, a registrar, or the public). Records management is often viewed as bureaucratic, but it is hard to imagine a process or system operating consistently without keeping accurate records.
Basic records management is straightforward — you need to decide what records you will keep, how you will keep them and for how long. You should also think about how you will
dispose of records once you no longer need them.
If your organization has an ISO 9000 management system, you should have a system for managing quality records.
Hints:
• Focus on records that add value — avoid bureaucracy. If records have no value, then don’t collect them. The records you choose to keep should be accurate and
complete.
• You may need to generate certain forms as you develop your EMS. These forms should be simple and
understandable.
• Consider combining your records management processes for environmental and health & safety records. • Establish a records retention policy and stick to it. Make
sure that your policy takes into account records retention
requirements specified in applicable environmental regulations.
• In designing your records management system, be sure to consider:
- who needs access? - to what records? - in what circumstances?
• If your organization uses computers extensively, consider using an electronic EMS records management system. Maintaining records electronically can provide an excellent means for rapid retrieval of records as well as controlling access to sensitive records.
• Think about which records might require additional
The Tool Kit contains a tool for organizing your filing system (see page 144). Copy the pages, cut out the tabs, and use them to set up
your files.
maintained at another location?
Types of Records You Might Maintain (Examples):
• legal, regulatory and other code requirements • results of environmental aspects identification
• reports of progress towards meeting objectives and targets • permits, licenses and other approvals
• training records
• EMS audit and regulatory compliance audit reports
• reports of identified nonconformities, corrective action plans and corrective action tracking data
• hazardous material spill / other incident reports
• communications with customers, suppliers, contractors and other external parties
• results of management reviews • sampling and monitoring data • maintenance records
• equipment calibration records
★ ISO 14001 requires that organizations have procedures for
training records and the results of audits and reviews ★
Review: Have we …
identified records to be maintained? determined their retention times?