What You See Is What You Get
What You See Is What You Get
During the interviews I had with EMS professionals, that included a mix of auditors from registrars, consultants moonlighting as EMS auditors, and RAB's own staff, I came away with a dearth of information that could be useful to dispel any misunderstandings into the EMS auditor process, what values they may have realized along the way, and how that factors into meaningful employment -which is the bottom line in these lean financial times.
The first person interviewed was Stan Fielding, Environmental Business Unit Manager at NQA-USA. Stan was gracious enough to answer a number of questions regarding how he views auditor accreditation. NQA-USA requires its auditors to be accredited, whether through RAB or any of the other accreditation bodies. He views accreditation as a pre-screening process that provides him a certain comfort level of the individual he's considering. In Stan’s view, accreditation is only the starting point. The person’s auditing style and practical experience are the key (hiring) issues. These were interesting points Stan raised that I shared with the other interviewees.
I next spoke with Jim Melloni, Environmental Business Manager at TUV America, Inc. Following up with the previous points Stan raised, I posed this question to Jim: if two auditors were looking for work with TUV, one with RAB credentials and one without them, who would he pick?
He would pick the RAB accredited auditor. On a more global focus (regardless of auditor accreditation), he would consider the more qualified auditor provided the auditor met the training and work experience requirements found in ISO 14012.
This particular point then led me to bring it up with RAB for additional clarification, as I later discovered in my discussion with their communications manager, Penny Frederick, while RAB does not impart any prohibition on RAB accredited provisional and environmental auditors, the fall-back Catch 22 is that registrars are bound by the requirements found in ISO Guide 66 and the supplementary IAF Guidance to Guide 66 that refer to the competency requirements found in ISO 14012.
In simple English, if a registrar can demonstrate that the auditor they chose satisfies all the boilerplate requirements found in these documents, that person can be part of an audit team. Whether they are RAB, UKAS, or whatever, accredited or not is immaterial. More on that later.
In general, Jim said that TUV sees RAB accreditation as a 3rd party independent verification of the auditor's qualification, and a measure that the auditor's background has been checked. He does offer this caveat though - just taking the (lead) course and then submitting an application to the RAB is not enough.
He recommends that prospective EMS auditors browse the RAB website and review the auditor qualifications to see how their own experience matches up with the listed requirements. In other words, getting the RAB "brass ring" is only the beginning, as we have established in our discussions so far.
The issue of whether RAB should require registrars to hire only accredited (EMS) auditors in the US, as is the practice in other professions that require credentials of their employees, such as in accounting, pharmacies, engineers, and any other public service profession, falls within the jurisdiction of several guidelines that transcend the RAB.
Other accreditation bodies, such as UKAS, SCC, RvA and DAR/TGA also follow these guidelines in other ISO member countries. As Jim stated, these are ISO/IEC Guide 66 and the accompanying IAF Guidance to Guide 66, the General Requirements for Bodies Operating Assessment and Certification/Assessment of environmental management systems that we previously alluded to.
All interviewees agreed that it is the higher standard set for auditors' competency and experience that each individual registrar looks for and requires in each auditor hired. If a registrar chooses not to view accreditation of its auditors as a gold standard, and instead hires on experience alone, tempered with their estimation of the auditor's competency, whether or not the auditor is credentialed, RAB or any other accreditation body will not penalize them.
That could be seen as an issue that is probably open to debate within the environmental community here in the US market. To call wider attention to this particular issue, the National Academy of Public Administration (NAPA) issued a report in 2001 that zeroed in on this very issue dealing with standard credentials for all EMS auditors, and among its findings stated that the EMS auditing and registration community should seriously consider developing a peer review system to maintain uniform professional norms of interpretation and practice.
Allowing registrars to set their own bar higher or lower depending upon their own business needs may not be in the regulated community's best interest. Let's not lose focus that organizations hiring registrars are the clients, and they are expecting value for their fair deal, not just a rubber-stamped certificate.
There is some speculation among the EHS community that one reason EPA has not given its full endorsement to ISO 14001 so far is their not-so warm and fuzzy feeling toward the current certification process. In our estimate, having a more robust peer reviewed auditor accreditation process coupled with a proviso that registrars, at least in the US, hire accredited auditors could add tremendous value to the EMS process, which is still maturing.
Our next interviewee, for various reasons, chose not to be identified, and we'll call that person the phantom executive from a registrar, also shares similar views with respect to the accreditation process for auditors. He feels that value is provided to a registrar if auditors are certified. In his company’s view, when certified, auditors meet a certain level of requirements and you know what they are up front. Whether they are RAB, IATA or IRCA certified, it says that they are experienced in some level of audits. You want auditors who are accredited on your team.
He also volunteered anecdotal information based on his own experiences with RAB's registrar and auditor staffers that he felt germane to the auditor accreditation process.
Consistency in reviewing auditor applications is just as important as determining auditor competency. Subjectivity in a review process, as is sometimes the case with registrars selecting their auditors for assignments, can introduce unknown factors that could be manifested in a less than satisfactory audit, as seen by the client (the auditee). He stated that RAB's customer service and response was less than satisfactory in issues dealing with auditors. Under the ISO tenet of continual improvement, he suggests the following:
1. RAB should work on its customer
service - more responsive to questions, and in
a timely manner.
He raised these issues because he feels there is an inconsistency between dealing with RAB's auditor and registrar accreditation staff.
Couple his observation with the NAPA report findings (regarding auditor consistency) and then add the fact that no structured format exists to require all registrars (in the US) to hire only accredited EMS auditors, one could argue that the EMS gatekeeper management system is about due for a review, just as ISO 14001 is set to be revised.
Change is good, as they say in the commercials. Or as Dennis Miller -former football color commentator, likes to say, “…That's just my opinion, I could be wrong.”
Allowing for equal airtime from both sides, I concluded my interview with Penny Frederick, Communications Manager for the RAB. She was gracious enough to provide RAB's view of several of the issues raised with my previous interviewees, including the presumption of any accredited auditor prohibitions during audits.
According to Penny, RAB has no prohibition on which type of auditors registrars can use during audits, although, the caveat is that if the auditors chosen do not meet the previously mentioned ISO Guide 66 Guidelines that refer back to ISO 14012, they would not meet the criteria to be part of an audit.
So, we are back to square one: auditor
accreditation is preferred by registrars, but if accredited auditors,
usually provisional or environmental, lack the requisite skills, and/or
the registrars they hope to work for assess their skills as insufficient,
they're on the sidelines. Is this widespread in the industry? I will let
readers ponder that question.
The Chicken or the Egg Top
So what did come first?
Or in our case, what matters most? Is it auditor experience and competence specified in ISO 14012, and referenced in ISO Guide 66, etc., or is it accreditation?
If it's accreditation, as most of my interviewees seem to agree, is the pecking order Lead Auditor first, followed by Auditor, then Environmental Auditor, with Provisional Auditor at the bottom? If the last two categories really don’t count in a practical sense toward auditor advancement, how did that evolve?
And the burning question - if registrars sometimes view competence over accreditation as a hiring qualifier for auditors, where’s the value to the EMS auditor for his or her investment in time and money to become accredited?
And, if they are either provisional or environmental auditors, when will they see a return on their investment?
This leads us to the core question, that if auditor accreditation is so important to the environmental management profession, (which I believe it is, regardless of level), then why isn't this aspect spelled out by the governing bodies and made a requirement for all registrars (in the US) to follow?
Putting this in perspective, how would you feel having Botox dispensed to you from an unlicensed practitioner? It may be a stretch, but it's relevant.
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