How to Conduct Internal Audits of Your Environmental Management System
Does
your EMS sit in a box on a shelf and look pretty or does it have the
stains, dings and scars of your favorite drill? ISO14001, the
International Standard Organization’s environmental management system
standard is, in the end, only a toolbox for the C-suite to achieve the
desired results of the business; be that cost containment, compliance
perfection, or an improved public image. What varies from organization
to organization is the use of ISO’s tools.
“Inspect what you expect” is a common-knowledge precept among
managers, especially for those concerned with producing a product or
service that meets customer requirements. The same can be said for
meeting a company’s environmental goals.
If an environmental management system is a living, breathing
organism, then internal audits are the central nervous system and, well
crafted and supported, they tell top management what processes are
working throughout the organization and what are not.
I often refer to EMS as the “Everything-else Management System”, by
which I mean that if “it” (whatever the subject may be) is not directly
related to the quality of the product or service that satisfies your
customer and keeps your workers safe, then “it” is an environmental
issue in two steps or less.
Think of it this way: if all pollution is waste and all waste is
pollution then anywhere you can reduce, reuse, recycle or use more
environmentally friendly material you have improved your environmental
impact and your sustainability as an organization. If you implement a
purchasing policy that all office furniture has to be made from
certified sustainable forests, for example, then you have stepped out of
the crowd that destroys forests and the creatures therein. If you
streamline a bureaucratic data processing system, you have saved
electricity, time and manpower. If you install a wind-turbine on the
back lot, solar panels on the roof, cisterns under the parking lot,
geothermal heat pumps, and paint the building a cheery bright green with
photo-catalytic paint then you’ve done even more.
But a common mistake I often see in certified environmental
management systems is an organization that does not identify the driving
mission of the EMS and the processes that accomplish the mission.
If the driving mission of your EMS is maintaining perfect compliance
then the processes – and people – who perform those functions are each
critical to your mission.
Similarly, if the driving focus of your EMS is cost containment and
you are not monitoring and measuring the fluid that leaks from your
machines, you cannot control the cost of fluid replacement, clean-up,
and disposal (not to mention slips, trips and other OSHA reportable).
The establishment of key performance indicators for environmental
processes is no different than establishing KPI’s for production
controls, product inspections, scrap rates, product delivery and
customer satisfaction. And just as in production control, potential
failure or breakdowns in the environmental management processes need to
be identified, monitored and prevented.
What you monitor and what you measure is what you control and what you improve.
Let’s say for the sake of example that your organization has
determined that to be competitive in the marketplace a “green” image is
an advantage. How do you maximize your sustainability and communicate
that to customers and suppliers without investing the capital for new
technology?
Start with purchasing and ask: have we evaluated what we buy based on
a set of standardized, systematic environmentally sustainable criteria?
Do we buy recycled content material? Have we evaluated our suppliers
for their commitment to preventing pollution, compliance with applicable
laws and continuous improvement of their management systems? Do we
choose a supplier with a certified management system over one without or
is price the only consideration? What are the indicators that tell me
my team is performing to my expectations?
Administration activities do impact the environment and must be
considered. Natural resources consumed by electricity, paper, heating,
cooling, furniture, fixtures, equipment, and travel all play an
important role in determining that your organization is not drawing more
from the earth than the earth can sustain. As the business plan evolves
and changes do we consider environmental impacts? And again, what is
that data that indicate the processes are in or out of control?
Key performance indicators and critical failure points must be as
integral to the environmental management system and internal audit
program as they are to the quality system, but sadly are often not.
Without the clarity of a road-map drawn from processes central to the
business plan and the mile markers of KPI’s, internal audits become an
exercise to satisfy outsiders, not top managers or drivers of business
improvement. Under the best of circumstances internal audits provide
objective feedback and suggestions for improvement that allow top
management to make intelligent, business-positive decisions. Under other
circumstances, internal audits can be a waste of time and resources.
The failure of internal audit programs is the failure to identify
what is important environmentally to the organization. Inspect what you
expect but first, be clear as to what you expect.
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