Leveraging
ISO 9000 for Environmental Management
System Documentation

by Caroline G. Hemenway and Gregory J. Hale

ISO 14001 doesn't require you to create massive
new document systems; build on the ones you already have in place.


Your company's had an ISO 9000 quality management system in place for three, four, maybe even five years, and you're just now getting used to writing down procedures and processes to improve the overall quality of the company's products, processes and services. Or you don't have anything at all resembling a documentation system.

Now your corporate office decides to implement an ISO 14001 environmental management system and you foresee an(other) avalanche of documentation requirements. What do you do?

Several experts suggest that you relax and build on any documentation system you already have in place. If you don't have one, remind yourself that ISO 14001 does not require you to create massive new document systems but to document certain specific procedures you probably already have and that probably already generate some kind of paperwork.

ISO 14000 is the international series of environmental management system standards being developed by some 50 nations worldwide under the auspices of the International Organization for Standardization. ISO 14001, the specification standard within the series, is due out as a final standard by fall 1996. ISO 14001 is modeled after ISO 9000 in many ways, and the two contain similar documentation requirements. In fact, ISO 9000 contains much more.

Ask yourself if the current documents
meet the needs of their audiences

Buy it off the rack
Experts agree that creating a document control system from scratch to meet ISO 14001 requirements is not necessary. They suggest taking the document control system your organization already has in place and adjusting it to include not only quality and environmental documents but also health and safety documents.

You don't have a quality management system in place? You had better get started now, experts caution, because management system integration is not only essential but inevitable.

There is a strong desire among industry representatives-who author ISO documents-to integrate elements of ISO 9000 and ISO 14001 once the latter is published and the marketplace has an opportunity to test it. Already, both technical committees within ISO are discussing plans to revise both sets of standards in 1999 so that they will be available to the marketplace by 2005.

The single greatest advantage of having an ISO 9000 system in place first is that the organization is already familiar with the systems approach and gets people used to documenting the processes and activities associated with their jobs, says Joseph Cascio, IBM program director for environmental health and safety, and chairman of the U.S. Technical Advisory Group to TC 207.

"A strict document control procedure-such as is required with ISO 9000-provides the basis for people to replace outdated documents, to track legal mandates for maintaining documents and to hold on to documents that may be associated with insurance liability," says Cascio. "Beyond that, ISO 9000 provides a template with an established structure and concept for your company to use when implementing any management system, not just ISO 14001."

Several companies are saving time and money by combining policy development, objective and target setting, training and corrective action requirements into one documentation system that covers ISO 9000, ISO 14001, health and safety, and other industry-specific programs.

For example, Texas Instruments is implementing ISO 14001 and is including documentation for health, safety and Department of Defense requirements in a single manual. However, only the EMS documents will be audited by a third party. The other documents are for internal use.

Akzo Nobel Chemicals Ltd., a BS 7750-certified company in the United Kingdom, combined quality and environmental manuals into one document. New procedures have been written, but most changes have been written into existing procedures. BS 7750 is the United Kingdom's EMS standard and formed the foundation for ISO 14001.

Millar Western Pulp Ltd. in Alberta, Canada, the first BS 7750-certified company in North America, added EMS-oriented amendments to its quality system document control procedures and referred readers to job responsibilities, authorities and training in the main quality management system manual. The company cross-references these requirements in the EMS manual and simply directs auditors to the QMS manual.


Frontload to avoid deadline headaches
To develop an effective ISO 14001 documentation system, you must work intensely in the beginning and simply tie up loose ends at the end, suggests Marie Godfrey, a management consultant specializing in developing management system documentation with Franklin Quest Consulting Group. This technique is known as "frontloading." People typically construct documents ineffectively by starting slowly and building to a frenzy before and often after the deadline, says Godfrey.

Frontloading includes planning the project, determining the format for all related documents, prototyping each document and scheduling writing and reviews. If you frontload effectively, says Godfrey, the people who know the content will be the ones who plan and structure the documents. Then, those comfortable with writing do the word processing, editing and proofreading.

The following four action elements to help companies perform an initial assessment of their current system were developed by John Earnhardt, an auditor with SGS International Certification Services:
· Become informed on emerging standards by reviewing recent drafts of the ISO 14001 guidance and specification standards.
· Assess the value of an EMS and ISO 14001 certification for your business.
· Perform an EMS review or gap analysis of where your company is and where it would need to be to implement and integrate the standards.
· Use the information to prepare a strategy for addressing and implementing ISO 14001.


Once this assessment is complete, the quality manager and the environmental manager should get together and discuss implementation and document development strategy, suggests Earnhardt. During this time, you should ask yourself if the current documents meet the needs of their audiences.

Documents not used might as well not exist, recommends Godfrey. She suggests you answer the following questions before proceeding any further:

Do the documents have:
· Purpose statements?
· Clear and logical organization?
· Content required for the job to be done as well as for meeting the requirements in the ISO standard being applied?
· Information presented in the most appropriate form (visually whenever possible)?
· Messages and supporting information conveyed through good writing techniques?


Documentation should be useful, usable and understandable, stresses Ian Durand, president of Service Process Consulting. EMS documentation should be written between an eighth- and 12th-grade reading level so that all employees can understand the documents, he advises.


Fill in the holes
Once you know what you need, you can develop a plan and schedule to create the missing documentation, says Godfrey. She suggests that your plan include the following elements:
· An environmental system manual that outlines the environmentally related policies and that addresses Section 4.1-Environmental Policy of ISO 14001.
· Procedures that identify all company processes and products that might affect the environment and that identify relationships of personnel, departments and processes.
· Work instructions that specify directions for a particular task (e.g., how to assess the effect of machine A on airborne emissions).
· Reporting forms that are templates to be filled in with data (e.g., incident reports, process information, training records).
· Large sheets of paper to construct a work-in-progress wall chart. This chart should be filled in as follows:
· List all documents needed. Group the documents in logical sets, according to production lines, etc.
· For each document, identify the people who will read and use it. Everyone must know and understand the contents of the EMS, but only a few people such as specific workers and supervisors are responsible for a single set of work instructions.
· Set a prototype date for each document.
· Leave space for writing deadlines and review dates.
· Identify the date of the next internal EMS audit.
· Use your company's internal communications system (e.g., newsletters, bulletin boards) to tell all employees what is happening and obtain their input.

"This is everyone's opportunity to run the company," says Godfrey. "Don't forget to include external communication such as stockholders and the nearby community."


Make technology work for you

The term "documentation" immediately conjures up images of burdensome corporate recordkeeping. But with advances in technology, electronic documentation is gaining popularity. However, it is too early to predict whether electronic documentation will displace paper because many companies and auditors say that both are important.

Durand prefers a hybrid system. "People who are used to a local area network will definitely go for electronic documentation, while paper has the advantage of easy access," he says.

On the other hand, some auditors say that paper documents may be examined more carefully. The main advantage of paper is that most people find it easier to read, but electronic documentation is usually easier to control and change, says David Hadlet, director of business development at Lloyd's Register Quality Assurance Ltd., which certifies companies to BS 7750, ISO 9000 and ISO 14001. The search engines built into many electronic documentation systems can provide an advantage, but when it comes to finding information about cost, either medium can have the advantage, depending upon the purpose of the search.

"The perfect management system-which, of course doesn't exist-will probably have a mix of both electronic and paper," states Hadlet.

Because companies are unique, you should design a documentation program that makes sense for your company, says Dawne Schomer, corporate environmental health and safety audit program manager at Texas Instruments.

EMS documentation is a natural outcome of a company's progression from a "firefightin" approach to environment, health and safety requirements, to having consistency among these programs, and to expecting continuous improvement and system excellence, says Schomer. Documentation requirements would only become a problem if documentation were viewed as an exercise without value or meaning.

"The hardest documentation task is the generation, issuing and reissuing of large quantities of procedures, which can be arduous and labor-intensive, especially in a large company," says Michael McBride, customer services manager for Smurfit Paper Mills in Ireland.

This disadvantage is being overcome gradually through the use of networked PCs. The document is fed into a master computer that is linked to other PCs, explains McBride. Any obsolete procedures are superseded or removed from the master computer, which eliminates the need for photocopying and circulating up-to-date documents frequently and by hand.


Involve end-users in prototyping
Before choosing between paper or electronic formats for documents that you prototype, begin by visualizing the end results you expect. Using a prototype is the most effective way to frontload the documentation process, advises Godfrey. She stresses that the best people to draw up document prototypes are the people who will use them.

The best way to develop prototypes, advises Godfrey, is to answer the following questions:
· What is the purpose of the document?
· Who will use it and how will they use it?
· Will some other size be more convenient than 8.5" x 11"?
· How long should the document be?
· What must be included in the document? Which information is most critical?
· What is the best arrangement of the information? Will the user read sequentially or randomly?


Using Post-it notes, large sheets of paper or any other convenient format, construct the document one page at a time, suggests Godfrey. At first, you simply place each main topic on a page. The pages will look quite empty, and you may be tempted to put more than one topic on each page.

Allot pages according to the importance of the topic, and be sure to plan for a table of contents, index, glossary, etc. This initial prototype should take two to four hours to create. By the time you finish, everyone should understand what the final document will look like and what it will contain.

"Flesh out the details of the pages by creating an interim prototype," advises Godfrey. Determine whether to use drawings, flow diagrams or other aids to help the user. Add headings and subheadings to create mock-up pages of the final document. But do not simply add pages as sections of text grow; pare the proposed information to its essential elements.

Flowcharts can be very effective in any management system documentation, including ISO 9000 and ISO 14001, says Hadlet. However, he warns you to recognize that flowcharts by themselves are rarely sufficient to convey information in the level of detail necessary to assure the appropriate consistency of operation. Include supporting instructions and/or evidence of "suitable training" to supplement the flowcharts, suggests Hadlet.

After developing the structure and presentation format of the documentation system, the time has come to write the documents. Assign writing tasks based on the person's knowledge and interest in the subject, suggests Godfrey. Then schedule a review of the interim prototype in a week or two. Displaying a prototype on a wall where writers can constantly refer to it will encourage them to tack suggestion notes to the documents.

By reviewing the documents as they are being developed, you can monitor the direction of the documents and point out obvious overlaps between quality and environment, which will help prevent duplication, according to experts.


Integration may not be for you

Integration is not for everyone because it depends largely on the maturity of the current systems in place. According to several experts, if your system is not very mature, you may find the advantages that come from a reduction in paperwork and time may not outweigh the need for more extensive coordination efforts between your quality management system and your EMS. If you did not take environmental, health and safety into account when developing your quality system, then integration may be a distant goal.

Having an ISO 9000 system in place eliminates the need for people to undergo a "mental paradigm shift" when preparing documents for ISO 14001", says Richard Paduska, director of health, safety and environmental affairs for Eastman Kodak Co. By using the rigid ISO 9000 philosophy-"do what you say and document what you do" -people are already regimented in developing process-oriented documents, he says.

But Paduska describes ISO 9000 as a horizontal system that stipulates that you manufacture a product to the quality agreed to by yourself and the customer. This is a continuous production process that produces a consistent product, he says. However, ISO 14001 is a horizontal system that ties every aspect of the system back into the EMS policy and is anchored by the concept of continuous improvement. ISO 9000 does not need senior-level support the way ISO 14001 does, Paduska claims. He adds that not only does ISO 14001 need it, but it will not work without it.

"Conceptually, there are many similarities between an ISO 9000 and ISO 14001 system, but realistically you may never be able to combine documentation for the two systems into one coherent management system manual," predicts Paduska. "It would be difficult for any auditor [internal or external] to pick apart pieces of the manual depending on the system being audited, e.g., quality, environment, health and safety, finance, resource allocation."

Kodak is considering integrating ISO 14001 with ISO 9000 in some of its European facilities but has not even considered integration for its U.S. facilities, according to Paduska. Internal audits in Europe will help Kodak flesh out the similarities between the two standards, he says.

The SGS-Thomson Microelectronics facility in Rancho Bernardo, California, recently became the first U.S. facility to achieve certification to both ISO 14001 and the European Union's Eco-Management and Auditing Scheme. While the plant is ISO 9001-certified, it did not leverage its ISO 9001 system heavily.

Documentation for the two systems is maintained in separate manuals but should be integrated by 2000, says Patrick Hoy, the site environmental manager. ISO 9000 provided a base but was not essential to implementing ISO 14001, explains Hoy. SGS-Thomson has mandated that all its facilities around the world implement and register to EMAS, but Hoy says not all facilities are ISO 9000-certified.

Dupont de Nemours Co.'s Safety, Health and Environmental Excellence Center will use ISO 9000 wherever possible to implement ISO 14001, says Barbara McGuinness, manager of environmental audit programs. However, ISO 9000-unlike ISO 14001-is not a corporate system and therefore no documentation exists at the corporate level. Without the use of ISO 9000 at this level, it will be difficult to identify where the two systems overlap.

"I am sure there are various overlaps associated with ISO 9000 certification," says McGuinness. "However, each of the 45 business units will determine where those overlaps fit into their existing systems."

About the authors . . .
Caroline G. Hemenway is publisher of CEEM Information Services in Fairfax, Virginia. Gregory J. Hale is associate editor of "International Environmental Systems Update," a monthly newsletter on ISO 14000 developments and implications. CEEM publishes "IESU" and several other ISO 14000 and other management systems products.

For more information, contact CEEM at (800) 745-5565 or (703) 250-5900; fax (703)