By Mary F. McDonald
Many organizations have more than one management system that they comply to—and the most common pairing in management systems is quality (ISO 9001) and environmental (ISO 14001) systems.
Because both of these management systems standards were updated in September 2015, many organizations are now looking to transition both systems to reflect the updated requirements of the standards. There’s good news for those that have one system that complies with both sets of requirements—both standards have adopted a common structure—Annex SL—that includes common requirements in many cases, common definitions, and even common text in some cases.
For groups that have separate systems, they will notice that the numbering, structure, and requirements are now much more closely aligned. They may want to evaluate whether they can combine their systems more closely going forward. Because there is a long transition period (until September 2018), organizations have plenty of time to review the requirements and determine if better alignment, combination, or integration is the right move.
Integration tips
So, what are these changes that potentially can make your life easier?
- Adoption of Annex SL. Because Annex SL is used to ensure that any management system standard is laid out consistently with the Annex SL model, all management system standards will now look similar with common terms, text, and definitions. This also means that even if a section of the older version of the standard has not changed, it may now be in a different section of the standard due to the clause element redesign.
- The good news: Everyone is now speaking the same language, referring to the same clause number regardless of standard (no more “5.6 if quality, 4.6 if environmental” for management review, as an example).
- The challenge: Many organizations write their documents referring to the standard. There is no requirement to renumber your existing documents to mirror the new clause numbers. So, it’s up to you to decide if you want to renumber your existing documents.
- Context of the organization. This is one of the most helpful clauses to those organizations that are fully integrated, as it requires an organization to look at itself in the context of integration—a quality system or environmental system cannot exist in isolation. Internal and external issues, risks arising from threats and opportunities, and interested parties all are taken into account when assessing the organization, and determining whether it is ready to transition.
- The good news: For integrated systems, this “forces” the organization to consider itself within a larger framework that extends outside its borders (interested parties, external issues) and assists in ensuring that the system is strong.
- The challenge: This requires the organization to do research and planning on what these issues, risks, etc. may be, and this can’t be whipped off in an hour meeting.
- Risk-based thinking. This is a new requirement for ISO 9001, but has been an integral part of ISO 14001 since its inception—in the form of aspect identification and impact assessment. The new standards require that an organization employ risk-based thinking to ensure that it is adequately addressing potential threats (negative) and opportunities (positive).
- The good news: For integrated systems, the existing aspects/impacts list simply has to be expanded for quality issues as well as environmental issues. The same tool can be used.
- The challenge: Because this is potentially “new news” for quality organizations (although they had previously done quality objectives, so it really shouldn’t be), they will need to formalize a methodology going forward to ensure that changes to the quality management system are reflected in the risk analysis.
- Management leadership and commitment. There’s no doubt about it—the new standards expect senior leadership to take a more active role in the management of the new management systems. This was intentional by the writers of the standards to embed operational and performance responsibility into the organization at all levels of management.
- The good news: Managers will be able to look at their systems as one holistic system in an integrated system. Does the pollution abatement actions affect the quality output of the product? Does the change in raw material to save a few pennies adversely affect our environmental footprint? This will allow them to make decisions based on a wider context, in alignment with risk-based thinking.
- The challenge: Senior management will have to step up to take a more active leadership role, and they may tend to revert to their previous tendencies (“Just keep me posted if there’s something you need me to do”).
Finally, there are some new requirements for ISO 14001:2015—scope and applicability, life cycle perspective, and control of outsourcing. There are also revised requirements in the areas of policy, communication, performance, and evaluation and management review. These will have to be incorporated into the organization’s management system to reflect new or updated requirements.
What about auditors?
Auditors also need to update their skills to meet the requirements of the standard. Auditors will need to:
- Understand context of the organization prior to auditing it to determine if the organization is meeting the requirement, and how this links to planning (clause 6) and operations (clause 8).
- Be flexible in getting sources of information, as the requirements for procedures and manuals is no longer in place.
- More strongly audit the process approach to ensure the interlinking of requirements is in place.
About the author
Mary F. McDonald is the CEO/CTO of McDCG, a management consulting firm based in Austin, Texas, that focuses on ISO, Lean/Kaizen, and process improvement. McDonald is a 30-year professional who has been involved in the U.S. TAGs for both quality and environmental management standards since 1995, and is the author of books and several articles on management system integration. She teaches and consults around the world and leads a team of talented individuals with expertise in quality, lean, environmental, health/safety, RoHS/WEEE, and industry-specific standards including automotive, aerospace, telecom, and medical devices. More info can be found at www.mcdcg.com or at www.linkedin.com/in/marymcd.