The current trend is to integrate the ISO 9001 and ISO 14001 standards, using and applying the common elements of both the systems (i.e. Management Reviews, Corrective Actions, Document Controls, Internal Audits). Registration companies encourage this practice through combined audits that allow a company to simultaneously obtain or maintain registration to ISO 9001 and ISO 14001. A company’s decision to commit to the principles of ISO 14001 will expand the scope of a company’s obligations and responsibilities, increasing the requirements of the ISO 9001 system.
Consider a simple piece of furniture made with medium-density fiberboard (MDF), a wood-based composite material. Now consider the impact of a simple finishing defect: one square millimeter of exposed substrate. From a strict, ISO 9001 quality assurance perspective, this is a minor aesthetic issue. The loss to society is, at worst, an annoying eyesore that can be touched up with chalk, ink, or a simple patch.
The situation changes when the furniture manufacturer expands the scope of its management system to include the obligations of ISO 14001. Since MDF is used as a key material for products, MDF and its component parts must be considered as significant environmental aspects requiring attention. The major environmental risk of using MDF is the risk of formaldehyde emissions. Formaldehyde is a toxic substance that causes irritation in the eyes and throat, which can lead to cumulative, permanent deterioration of health. For this reason, governments in Canada and the United States have explicit regulations addressing this issue. In an attempt to prevent MDF from total recall and prohibition (the fate suffered by producers of urea formaldehyde foam insulation), a specific set of industry requirements has been established to contain the formaldehyde and prevent it from emitting at excessive levels.
Based on this new information, an area of exposed substrate, even one as small as one square millimeter, can be considered a significant defect resulting in a potential environmental hazard. The loss to society is expanded from an aesthetic defect to potential air quality contamination, health risks, and environmental pollution.
What does this mean for an existing ISO 9001 quality assurance system? The expanded scope will have to be addressed in the different elements of the quality system. ISO 9001 is not a quality assumption system; it is a quality assurance system. The furniture manufacturer is required to provide objective evidence that its products that contain MDF do not present an environmental hazard.
No longer is it tolerable to simply cover the exposed MDF substrate with a piece of chalk, ink, or a simple patch since these are not acceptable barriers to formaldehyde emissions. Instead of a quick fix, an audit must be conducted to answer the following questions:
- Was the MDF produced according to ANSI A208.2 standards?
- Was the MDF sufficiently aged?
- Was an adequate barrier applied, in the manner directed by industry-approved guidelines?
- Would this MDF piece pass the test protocol outlined in ASTM D5014-94?
- Would this MDF piece emit formaldehyde at a level exceeding the regulated limits?
In conclusion, the augmentation of ISO 14001 requirements to an existing ISO 9001 quality assurance system will expand the scope of the management system and require expansion of the quality system elements to address the expanded scope. A company that is unprepared to escalate the quality system to an appropriate level and provide adequate and sufficient resources to ISO 9001 compliance should carefully consider its decision to commit to the principles of ISO 14001. Otherwise it may find itself overwhelmed and unable to fulfill its explicit obligations.
Dan Zrymiak is a senior member of the American Society for Quality, presently serving as the Region 4 (Canada) Deputy Regional Councilor for the ASQ Software Division. He is employed as a Quality Systems Specialist with A.L.I. Technologies Inc., Richmond, B.C., Canada.