Typical weaknesses as recognised by EMS auditors: FOR ALL INDUSTRIES IN DEVELOPING COUNTRIES ITS FOR DEVELOPMENT AND IMPROVEMENT

Typical weaknesses as recognized by EMS auditors:

FOR ALL INDUSTRIES IN DEVELOPING COUNTRIES

ITS FOR DEVELOPMENT AND IMPROVEMENT

  Failure to identify and manage key aspects e.g. design, contractors, projects

  Failure to identify, demonstrate, periodically evaluate legal compliance issues e.g. Duty of Care

  Failure to maintain records to demonstrate clause requirements are implemented e.g.communication, testing of emergency preparedness procedures

  Failure to complete management review

  Failure to continually improve i.e. repetition of targets not achieved, ongoing legal compliance/monitoring & measuring

  Failure to monitor objectives and targets

  Failure to quantify improvements

  Decreasing Management Commitment

  Reduction in environmental awareness

  Failure to analyse data

  Objectives and targets not driven by EMS

Define Success for our EMS

Establish Performance Measures

Refine the Corrective/Preventive Action Process

Keep an EMS champion

Spread EMS Responsibilities

Perform Semi-Annual Audits

When to Consider Control Points?
During the stages of EMS development, some control points require more time and energy than others.

Beginning: EMS Under Development. Defining success and developing metrics are the two most important control points at this stage.

Developing: EMS Registered/In Conformance. Further developing the corrective/preventive action process and internal EMS audits, and solidifying responsibilities for the EMS, should be priorities early in the deploying stage. Metrics should continue to become more sophisticated.

Maturing: EMS as a Business Practice. Defining success, establishing performance measures, and refining the corrective/preventive action process should be ongoing activities at all stages of EMS development. By the maturing stage, however, the critical control points of keeping someone in charge at the plant level, spreading the responsibility, and performing semi-annual audits have already been addressed.

Define Success for our EMS

If you don't know where you're going, you'll end up someplace else

An EMS may be considered a success if objectives and targets are being met and internal audits reveal few non conformance. But remember that no implementer does not define success for the EMS; senior management must do this. The EMS must meet management's goals and expectations in order to continue to enjoy resources.

Be sure you have a clear and complete understanding of what the EMS must do/be/deliver in order for management to consider it a worthwhile investment. Management's definition of success may not go beyond a simply stated goal such as registration. The implementer may have to educate management on how the EMS can be utilized to meet business and financial goals.

While senior management controls the EMS purse strings, another important component of EMS success is its perceived value among employees. Is the EMS seen as needless paperwork or as a system which helps manage change? Are the procedural requirements a burden or are they simply the way business is conducted? Are the objectives and targets being supported? An EMS that is not being supported will not reach its full potential.

Defining success for the EMS is most critical very early in the process, when you are devising the plan for EMS implementation. However, it is not a one-time process. The definition will change over time, particularly once registration has been achieved. Therefore, it is important to periodically reconsider your organization's definition of a successful EMS.

Establish Performance Measures

What gets measured, gets managed -

Performance measures reflect the quantitative and qualitative results of an EMS; they are used to track progress toward the goals defined by management. EMS performance measures are often thought of as simply quantifiable objectives and targets. In fact, however, they also include qualitative measures of how larger business goals - such as reducing liability or improving public perception.

Refine the Corrective/Preventive Action Process

An ounce of prevention is worth a pound of cure -.

One of the strongest characteristics in any EMS models is the strong "continuous improvement" component. Fundamental to the continuous improvement cycle is the corrective and preventive action process. Yet this important link is often the weakest in many organizations, even registered companies.

Corrective and preventive action is logically one of the last requirements any company implements. The process or procedure developed often has not been tested to any great degree at the time of registration and typically is used only in response to non conformances resulting from an internal audit.

Keep an EMS Leader

Action springs not from thought, but from a readiness for responsibility

Once the immediate goal of EMS registration is achieved, an organization may be tempted to think, "We don't need an EMS implementer anymore. We have achieved our goal. The system will now run itself." The fact is that no system runs by itself.

While it is true that you do not need an individual or team to spend as much time on the EMS as they did during in the beginning stage, you still need someone to lead the development process. The implementer must help ensure that the EMS continues to function as designed (e.g., that corrective actions are completed and EMS audits done) and to champion the process of EMS development. By keeping an implementer in place, management conveys the message that yes, even though we have achieved registration/conformance, the EMS is still supported by management and remains a performance expectation.

Spread EMS Responsibilities

We have only one person to blame, and that's each other - Berry Beck.

Regardless of the size of the facility, it is easy to allow the environmental management system to become "Joe's EMS" - meaning that one person drives the process. Joe writes all the procedures, does all the training, and is responsible for implementing most of the objectives and targets. When Joe leaves - not if, but when - the EMS, and the investment the organization has made in it, are in jeopardy.

A remedy for this problem is to keep in place the cross-functional team that was formed to help with implementation. A team is a great source of ideas. It also deepens the knowledge base for the EMS, and communicates the message of the EMS to the shop floor, to the all-important line supervisors, and throughout the organization.

The cross-functional team can also help the implementer integrate the EMS into other facility systems, such as quality assurance or health and safety. In addition, the team can assist in determining how the EMS can support new initiatives such as life cycle assessment, and in demonstrating the value of the EMS to facility and corporate management.

Perform Semi-Annual EMS Audits

In God we trust. All others we audit –

Organizations seeking EMS registration often have complete, but immature, systems in place. Critical adjustments may need to be made in the EMS over the formative first two years. There are often misunderstandings about standard requirements that have gone unchallenged by the internal audit program. A common one is, "You mean I don't need an objective for each significant aspect?"

If your organization has third-party registration, request a semi-annual audit schedule from your auditor (instead of an annual visit) for at least the first few years. The number of audit days for annual and semi-annual surveillances can remain the same. While the semi-annual schedule interrupts operations twice, rather than once, per year, the advantages outweigh the disadvantages. After registration, there tends to be a perception that the EMS project is over and that now management and employees can move on to other projects. Semi-annual surveillances by the auditor help ensure that senior management continues to provide resources, that management continue to support the EMS, and that employees actually use the procedures or work instructions devised.

In addition, you should space your own internal EMS audits no more than six months apart. You do not have to audit the entire EMS every six months. Instead, pick the areas to audit based on the environmental importance of the activity concerned and the results of previous audits.

If your auditor comes in once a year, schedule your internal EMS audit at the half-way point as a check. Otherwise, weaknesses, misunderstandings, or misinterpretations can continue for extended periods of time. Do not wait until two weeks before the surveillance audit to do your own internal EMS audit. This is particularly important in the development.

BY.

Dr. AMAR NATH GIRI