Although not the ideal substitution,
quality managers can step in for environmental efforts.

______________________
by Vanessa R. Franco

Chances are you became a quality professional because you believe in the intrinsic value of quality. You understand the theories and know how to effectively use the tools for implementing a strong quality management system, and you've likely dealt with the challenges of ISO 9001 registration. So why should you care about ISO 14001?

Five for the Field David G. Farrell, manager of FLS Consulting in Thunder Bay, Ontario, Canada, offers the following tips for easing ISO 14001 implementation:   Begin using an electronic documentation system as soon as possible. Some very good software exists to help you "document what you do, do what you document, and prove it." You will probably find you're doing most of the right things already; you just need to formalize them. The more user-friendly and nonlabor-intensive the system for accomplishing this, the better.   Share the responsibility and work as a team. Remember to include all employees at all levels of the organization. The "many few" factor can make a difference: If I recycle two pounds of waste a year, it's not significant, but if I have 1,400 people each recycle two pounds of waste a year, it becomes significant.   Set the scope of your project. You can't do everything at once, but you can set an objective to go beyond the standard's minimum requirements and maximize payback.   Consider hiring consultants, but make certain they will help build your vision (rather than their idea) of what your system should be. You're the expert when it comes to your business; the consultant is the expert on management systems. Consultants can be real time savers and are effective for stimulating change in an organization's culture.   Remember that training is part of implementing. Environmental issues have a high profile, and providing your employees with awareness training will help create the desire to get involved.

 "Any good quality professional, especially a quality manager, should be familiar with the latest trends in management systems," says Stan Fielding, ISO 14001 Business Unit Manager at National Quality Assurance, USA. "A quality manager should always be examining new trends to determine whether and how each trend could be beneficial to his or her company. If the company is out of compliance with environmental regulations or could lower its impact on the environment and, at the same time, increase profitability, all managers (including the president of the company) should be interested."

 This is all well and good, but what happens when you, a quality manager, are asked to attain more than a basic familiarity with ISO 14001--when you're instructed to play environmental expert and spearhead a movement toward ISO 14001 registration or compliance? Suddenly, you find yourself out of your element. What's a quality manager to do?

 "Putting a quality manager in charge of ISO 14000 efforts is not a solution to be encouraged," says Jack Kanholm, author of several books on ISO 9001, QS-9000 and ISO 14001 available through AQA Press. "Here are the facts: Large companies have environmental positions already established (e.g., vice president of environmental protection), and these people will take responsibility for ISO 14001. In medium-sized companies, you might combine a few duties, but there will still be 'environmental' positions: for example, manager for health, safety and environment. Only very small companies, such as those with, say, fewer than 400 people, have no one specially designated to handle environmental issues, and these companies will often assign the quality manager to the task of achieving ISO 14001 compliance. They choose the quality manager because ISO 9000 and ISO 14001 are structurally similar, not because a relationship exists between quality and the environment."

 In other words, you'll be facing some unique challenges as you try to make this leap. With proper preparation, though, the task can be made more manageable.

Keeping your eye on the ball

 Every change effort needs employee buy-in to succeed, and if you've been thrown into the position of coordinating environmental endeavors, it's likely that the first person you need to convince of the task's worthiness is yourself. Staying focused on your goals will help you do this. Fortunately, says David G. Farrell, manager of Canadian-based FLS Consulting in Thunder Bay, Ontario, myriad potential advantages can justify investing in an ISO 14001 environmental management system:

  Customers prefer to deal with environmentally responsible companies. The leadership approach demonstrated by responsible companies should be recognized and encouraged.

  International standards can help ensure a company's competitiveness in world markets. In many industries, ISO 14001 registration may not provide a competitive advantage, but it may someday be a prerequisite for doing business.

  Investors seek companies willing to take an environmental stand.

  A company's environmental commitment fosters employees' increased environmental awareness. Employees take pride in their company being a good corporate citizen, and the knowledge gained is transferable off the job.

  Such a system facilitates communication with all stakeholders, including employees, communities, suppliers and--especially--customers in today's world of heightened environmental awareness.

  This initiative provides a plan for continual environmental improvements.

 "ISO 14001 registration can provide an effective tool for increased awareness and understanding throughout an organization," Farrell summarizes. "An organization that is committed to and properly designs and executes this program can expect to have improved environmental management in all areas, thereby improving environmental performance.

 "The motivation to get ISO 14001-registered should lie in working toward the improvements made possible by use of the system, not in attaining the piece of paper. Many companies are internally complying to ISO 14001 and self-declaring. The benefits include the development of a systematic approach, standardized work practices and senior management's confidence that all employees are taking responsibility for the environment."

 ISO 14001, much like ISO 9001, can provide the framework for continual organizational improvement. Fielding notes that ISO 14001 registration can keep employees on their toes, actively working to develop new ideas to improve processes. "When programs don't receive much attention, most people tend to give them lower priority over time," he says. "A surveillance audit every six to 12 months gives people a reason to periodically spruce up the system. A value-added audit can provide new ideas: the auditor can question the status quo, give examples of other effective techniques for handling problems and bring news of fresh technologies that could prove useful."

 Lest you think that the benefits of an ISO 14001-compliant EMS are limited to self-congratulatory pats on the back, Kanholm notes that the standard also can have the very tangible effect of decreasing potential legal liability by bringing a company into compliance with federal, state and local requirements. It can also help an organization realize significant savings. "I see it often with hazardous waste disposal, which is very expensive," he says. "ISO 14001 causes a company to examine its waste streams and start reducing them at the source. That's more of a one-time big bonus. But savings can also be realized through recycling and controlled energy usage."

Bureaucratic benchwarmer or environmental all-star?

 There's no denying that ISO 14001 hasn't enjoyed anything like the popularity in which ISO 9001 is currently basking, but it's not really an even comparison. Drivers for ISO 14001 implementation are quite different from those of the ISO 9000 standards, and different from what they were originally thought to be, as well. Nonetheless, there are still good reasons not to ignore ISO 14001.

 "Five years ago, when ISO 14001 started, we thought that being a good citizen would be a market driver for promoting the standard's implementation," says Kanholm. "It turns out it's not. The general public never really found out about it, so there's not much of a benefit to be had in terms of impressing the customer. The Environmental Protection Agency never integrated ISO 14001 into its regulatory regime, though it does use it in settling individual cases. But without these external drivers, you don't see the push for registration like you do with ISO 9001.

 "However, even though it's more sluggish than ISO 9001's, ISO 14001's primary driver is the same: OEM requirements--pressure from the big customer."

 It's worth noting, too, that ISO 14001 registrations are climbing, albeit at a more sedate pace. "The standard is becoming more accepted by U.S. companies and the U.S. government," says Fielding. "There's more growth in ISO 14001 due to mandates from the automobile manufacturers on their suppliers, from the federal government on federal facilities, and from foreign companies and governments on their U.S. suppliers."

Six Steps for a Smooth Swing   Attain basic knowledge of environmental issues and vocabulary.   Set an environmental policy.   Write your procedures according to the standard and your organization's requirements. Don't forget that significant environmental aspects are the governing factor in your system, and identify the boundaries to be addressed.   Train everyone on his or her responsibilities. This usually includes a core or generic EMS package for your company and a job specific module.   Self-declare conformance to the system: Implement it and live by it.   Internal audit after the system has had a chance to accumulate some history. Correct any deficiencies and hold management reviews of your environmental management system, including the status of your continual improvement projects or programs.

Know the rules of the game

 ISO 14001's structural similarity to that of ISO 9001 is likely the very thing that got you into the position of shepherding your organization's ISO 14001 system, so at least the skills you've obtained through ISO 9001 implementation will transfer to ISO 14001 implementation.

 "There is very little difference between the planning, documentation and auditing requirements of ISO 14001 and those of the new ISO 9001:2000," says Farrell. "The skills are the same, and the framework is very similar. To achieve certification, the facility is required to have an environmental management system in place that complies with an internationally accepted set of guidelines or standards for environmental management. The ISO 14001 standard focuses on systems, continual improvement and documentation. Registration requires an extensive audit process conducted at least annually by an impartial third party. I recommend integrating quality and environmental systems and audits, and while you're at it, you should consider integrating your organization's occupational health and safety management system, as well."

 Beyond structure and some methodology, however, ISO 14001 will be foreign territory to most quality professionals. So where should a beleaguered quality professional begin?

 "Quality managers in this position have basically two options: to team up with environmental engineers and/or to try to educate themselves," says Kanholm. "The first step would be to examine ISO 14001 and learn the subtle differences between it and ISO 9001. Then, it's crucial that the quality manager conduct a gap analysis of his or her own skills. The most vital task facing the quality manager-cum-environmental manager will be developing enough knowledge of environmental protection issues (including the media, or air, water and land; hazardous substances; laws and regulations; and storage). These don't need to be killers, most of this is pretty benign stuff. The quality manager's starting point, then, should be to get some form of environmental engineering training, be it through books, seminars or other means. Forget the "how to implement" approach. Realize that it is going to take time--perhaps a couple of years--to really start to catch up on the legal requirements and issues and the specialized vocabulary.

 "Development of specific goals is also key; determine what you need to do to comply and ensure continued compliance. ISO 14001's primary difference from ISO 9001 is the "environmental aspects," which require that you determine how your organization's operations affect the environment and how significant these effects are. From there, select a few to control and improve performance."

 So what are these "environmental aspects"? ISO defines them as "elements of an organization's activity, product or services that can interact with the environment… A significant environmental aspect is an environmental aspect that has or can have (potential for) a significant environmental impact."

 But what does this mean to your organization? "It means you systematically look at what you do and produce and determine the risk of it affecting the environment negatively or positively," Farrell explains. "If the aspect of that activity has legal control to mitigate any impact on the environment then it is automatically significant. A rating system is determined by the company that can take into consideration such things as public opinion, cost, scale of impact, severity and probability of impact. You consider the normal, abnormal and reasonable foreseeable or emergency situations. Once you've identified the significant environmental aspects, you can ensure that you have the resources and systems necessary to control those aspects. It's very important that all people who do work that could influence a significant environmental aspect are not only aware of their responsibilities and the results of their actions but also have the tools necessary to mitigate the risk. Once you've done so, you'll have the template to look at the significant environmental aspects of your operation and identify opportunities for continual improvement by setting environmental objectives."

Environmental coaching

 No matter how well you've trained yourself, you're likely going to need some help along the way. Fielding recommends finding an environmental lawyer or consultant with regulatory knowledge who will be able to identify the legal requirements, develop a program to evaluate compliance to environmental regulations and implement it, develop or review compliance-driven procedures (such as those for handling hazardous materials and waste management), identify retention times for records pertaining to regulatory compliance, and train top management on regulatory responsibilities.

 Kanholm agrees that obtaining the services of a good lawyer is highly advisable. But keep in mind, he warns, that an inherent conflict exists between ISO 14001, which calls for transparency or open communication, and lawyers, whose job it is to prevent the company from incriminating itself in any wrongdoing.

 Finally, you might want to look into hiring a consultant, and if you plan to become registered, you'll need to find a registrar. "In looking for a registrar or consultant, seek out people who will listen to the company, be flexible on how to approach an issue, and place the company's interests first," Fielding advises. "The only things someone should impose on the company are the requirements of the ISO 14001 standard. There are many different and effective ways to meet the ISO 14001 requirements, and the best will fit into the company's existing culture."

Step up to the plate

 If, as a quality professional, you aren't responsible for your organization's environmental management system, you can be grateful that your company has the resources to allocate these duties as is most appropriate: to environmental experts. Still, there's no reason that you shouldn't take the time to at least familiarize yourself with your company's EMS, because effective companywide communication requires that there be some overlap--even indirect--at virtually all levels, including managerial systems. If, however, you have been sought out, due to your QMS background, to look after an EMS destined for ISO 14001 registration, you won't be facing an easy task--but it's not impossible either. Try to approach it as a way to broaden your knowledge base and add a little variety to your workday. Lay the foundation with self-education, and you'll be on your way to leading your organization to environmental management system excellence.

About the author

 Vanessa R. Franco is Quality Digest's managing editor. Please e-mail comments about this article to vfranco@qualitydigest.com.