Leveraging a Quality System To Establish an EMS
Similarities are many; differences are few
by Marilyn R. Block
Despite overwhelming similarities between ISO 14001, Environmental Management Systems--Specification With Guidance for Use and ISO 9001 based quality systems, the vast majority of quality assurance managers are as unfamiliar with ISO 14001 today as when it was published in 1996.
The current ISO 9001 revision effort, with its focus on compatibility between the two standards, exacerbates the misperception that implementing ISO 14001 within a quality registered company is difficult at best. With publication of ISO 9001:2000 anticipated shortly, an overview of the similarities between the two standards is warranted.
The 18 numbered elements contained in ISO 14001 are loosely organized to reflect planning, implementation and evaluation activities. The greatest differences between ISO 14001 and ISO 9001 are found in the area of planning. Implementation and evaluation requirements are almost identical.
Among the five environmental management system (EMS) planning elements, ISO 14001 requires identification of environmental aspects and evaluation of their impacts. Simply stated, an aspect is any element of an organization's activities that can interact with the environment.
Take paint as an example of an aspect. An environmental impact would be a change to the environment that results from an aspect--for example, emission of volatile organic compounds into the air, or land or groundwater contamination resulting from disposal of used paint containers in a landfill.
There is no comparable requirement in ISO 9001; however, once environmental aspects and impacts are identified, remaining planning elements are remarkably similar. ISO 14001 requires development of an environmental policy statement, just as ISO 9001 mandates a quality policy statement.
ISO 14001 also requires the articulation of environmental objectives and targets and establishment of a formal program to achieve them. These activities are similar to the quality planning component in ISO 9001.
Finally, ISO 14001 planning efforts require that an organization is knowledgeable about its environmental legal obligations. ISO 9001:1994 does not directly address this issue; however, it is indirectly addressed under process control, which does require compliance with reference standards and codes.
QS-9000, the automotive derivative, is more explicit--the purchasing element refers clearly to government, safety and environmental regulations. And ISO 9001:2000 contains a note in the section on customer focus that stipulates the importance of regulatory and legal requirements.
Of the seven implementation elements in ISO 14001, five are virtually identical to quality standard requirements. EMS requirements about structure and responsibility mirror quality requirements dealing with definition of responsibility and authority of personnel, provision of resources and designation of a management representative.
The EMS training element also reflects ISO 9001 training requirements. Both standards mandate the identification of training needs, provision of training for specified personnel and determination that personnel performing certain tasks are qualified to perform those tasks. ISO 14001 imposes one additional requirement pertaining to general awareness training for workers in relevant functions.
Both standards require system documentation, although ISO 14001 does not specify, as does ISO 9001, that such documentation be in the form of a manual. Both standards also require document control procedures that ensure that procedures and other documents related to the requirements of the standard are appropriately established, approved, reviewed, revised and current.
The EMS operational control requirement, which specifies procedures and work instructions for tasks associated with significant environmental aspects, is virtually identical to the ISO 9001 process control requirement covering production, installation and servicing procedures.
ISO 14001 also stipulates that procedures related to the environmental aspects of goods and services provided by suppliers and contractors must be established and communicated. The closest requirement in ISO 9001:1994 is embedded in evaluation of subcontractors. Although ISO 9001:2000 replaces the words "evaluation of subcontractors" with "purchasing control," it retains the same language about supplier ability to provide product in accordance with the organization's requirements.
Communication and environmental preparedness
The two EMS elements for which no comparable requirements can be found in ISO 9001:1994 are communication and emergency preparedness and response. ISO 9001:2000 contains two references to communication. The requirement to ensure communication between various organizational levels and functions reflects the ISO 14001 requirement for internal communication. And separately, there is a requirement for customer communication that is similar to the ISO 14001 requirement regarding communication with external interested parties.
With respect to the seven ISO 14001 requirements that contribute to evaluation of the system, only one--evaluation of regulatory compliance--differs from quality system activities. All other evaluation requirements are similar, if not identical, to ISO 9001 requirements.
ISO 14001 requires that all operations and activities that can have a significant environmental impact are monitored and measured regularly. This is analogous to the quality process control requirement to monitor process parameters and product characteristics.
ISO 14001 goes on to stipulate that monitoring equipment must be calibrated and maintained--a requirement virtually identical to the ISO 9001 element about control of inspection, measuring and test equipment.
Internal system audits are mandated by both ISO 14001 and ISO 9001, and both standards address corrective and preventive action in response to identified system nonconformances.
Difference in preventive action
A notable difference between the two standards concerns the approach to preventive action. In a quality system, preventive action refers to activities designed to avoid a nonconformance. In an EMS, preventive action pertains to activities intended to keep a nonconformance from happening again.
Both standards impose the same requirements on the identification, maintenance and disposition of records. Finally, both standards require that senior management review the system on a regular basis.
An element-by-element comparison of ISO 14001 and ISO 9001 reveals that only five issues that must be addressed by an EMS are not required by a quality system:
1. Identification of legal requirements.
2. Evaluation of regulatory compliance.
3. Emergency preparedness and response.
5. Environmental aspects.
Interestingly, four of these five issues are addressed within companies anyway, although this usually occurs outside the boundaries of the quality system.
The environmental function typically identifies an organization's legal requirements and takes appropriate steps to determine whether the organization is in compliance. If these activities are not already captured in documented procedures, it is a relatively straightforward process to formalize established practices.
Similarly, the safety function typically identifies the potential for accidents and emergency situations and develops response plans that can serve as the foundation for fulfilling the EMS requirement. Existing response plans often require little more than some expansion to ensure that potential environmental incidents are identified and reflected in emergency procedures.
Although communication plans are rarely captured in the form of documented procedures, all companies maintain internal and external communication practices with a variety of individuals, functions and groups. Therefore, the creation of procedures for purposes of fulfilling the ISO 14001 communication requirement tends to be relatively straightforward.
It is probably fair to state that the only truly new activities imposed by ISO 14001 revolve around the need to identify the environmental aspects and impacts associated with a company's operations and activities and the goods and services provided by suppliers and contractors.
Contrary to the implication fostered by the revision effort of ISO Technical Committee 176--that ISO 14001 and ISO 9001 are incompatible--it should be apparent that the two standards are remarkably alike in many areas.
Growth of ISO 14000 implementation
As increasing numbers of companies implement ISO 14001, either as the result of a voluntary senior management decision or at the behest of a customer, organizations already registered to a quality management system will enjoy a distinct advantage because existing quality procedures can be used with only minor modification to fulfill EMS requirements.
Procedures such as identification of training needs, document control, internal audits, records and management review are as applicable to an EMS as they are to the quality system for which they were created.
The ability to use quality procedures has significant resource implications. An entire EMS can be designed and implemented in approximately half the time in a company registered to a quality management system as is needed in companies that do not have quality systems in place. Moreover, the number of common requirements simplifies the task of ensuring employee awareness and understanding of the EMS.
There are many issues that must be addressed in making the decision to implement an EMS. However, compatibility with an existing quality system is not one of them.
MARILYN R. BLOCK is president of MRB Associates, an environmental management systems consulting firm. She earned a doctorate in human development from the University of Maryland College Park. Block co-authored the Quality Press book Integrating ISO 14000 Into a Quality Management System and authored Implementing ISO 14000 and Identifying Environmental Aspects and Impacts. She is a member of ASQ.
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