Gabriele Crognale

For many EPA regulated companies, staying abreast of mandatory compliance requirements is usually first and foremost on their radar screen when it comes to environmental and health and safety considerations.

As these companies see it, having a management system in place that provides for the organization to be certified to ISO 14001 (commonly referred to as an environmental management system, or EMS) is a noble cause, but is not worth the capital expenditure and staff time to implement to completion - unless of course, a company is in an industry where the main customers demand it from their Tier 1, Tier 2 and so on, suppliers, such as in the automotive industry.

So, why the dichotomy? Let's look at this in greater detail, and perhaps we can determine exactly what ISO 14001 can provide, and whether there is any tangible merit to such a time-and-money-intensive system.

A Few Practical Considerations of an ISO 14001 program

	Certain processes or operations viewed strictly as a compliance issue may not provide opportunities for minimizing waste products or waste streams; whereas, incorporating waste minimization or efficient material throughput program(s) into such programs via a series of ISO-focused targets and objectives identified by specific procedures can make a measurable difference.
	With respect to compliance, having a system in place that allows required documents and plans to be linked to elements of ISO 14001 provides an organization the opportunity to ensure that such documents are incorporated into the EMS, rather than viewed as stand-alone documents without a "home". Such linkages strengthen an EMS while providing multiple opportunities for continual improvement.
	With respect to continual improvement - another key tenet of ISO 14001 - an EMS that is established and is consistent and methodical in its execution by various employees will eventually provide clues by way of internal audits or management reviews, which areas need improving to increase the effectiveness of the EMS in place.
	Based on what our client's experienced, we offer the following anecdotal information to reinforce the preceding bulleted items:

Jump Starting the ISO Program

While some ISO practitioners may want to start with a Gap Analysis, we feel that a more prudent approach would be to strategize with key players within the organization what they want and expect from ISO 14001, whether they can muster a handful of employees to volunteer to become the Core or Implementation Team (the "Iteam"), and what their time frame may be for pursuing ISO certification from an outside registrar - not necessarily in that order.

From out experience, we feel that such an approach can provide more tangible results - translate that to value for the client - as well as save tools such as a gap analysis, or a pre-assessment, for later in the EMS program development, when these can be used to flush out any system shortfalls that may lead to nonconformances in the EMS and be potential concerns for the registrar.

Of course, jump starting an organization's ISO/EMS program does require considerable effort on the part of the organization, and how much of that responsibility the organization may be willing to tackle also needs to be discussed beforehand.

In this initial program, each organization needs to realistically assess where it stands with respect to staff competence and resources, and how much additional organizational support they may expect to receive over the course of developing the EMS. While some organizations may have robust EHS and QS staff on board, where a number of employees are versed in EHS and ISO 14001 considerations, others may be starting from scratch, and may need to look outside for professional implementation and training assistance.

Fortunately, this area is very well followed by industries and service providers alike, and a wealth of information exists out there. Unfortunately, there is no ISO equivalent to Gomez.com, so some organizations are forced to rely on word-of-mouth from their peers, or need to spend considerable time researching the matter themselves to find what is best. That approach, in of itself, is not futile, and actually provides the greatest amount of value. It also helps to ask the right questions to get the answers you seek.

Getting There from Here

Let's say that you have done your homework, you have your Iteam assembled and have a fairly solid idea of what you want to accomplish, what next?

Viewing this from the perspective of organizations in the cleaning process industry, the crucial first step is to have your Iteam thoroughly understand all the processes within your plant or facility. That is key because you will need to know this information to delve into the first step in the ISO 14001 implementation process: determining aspects and impacts.

If anything, the amount of time spent in the ISO implementation process, eventually becomes an investment to the organization, and this is one area where being cost conscious gives new meaning to being "penny wise and dollar foolish".

Why? Because everything else follows from these two important keystones in the ISO process. The time spent includes such items as going through exercises with the Iteam to determine aspects, identify their impacts and ranking the significance of each impact identified, providing awareness training to operations employees who are not part of the Iteam, culminating in establishing a ranking of the most significant impacts.

For example, in the cleaning process industry, some processes that would be considered as aspects could include: PC board or other metal or composite parts cleaning, damaged or off-spec assembled components, or other line processes. Their respective environmental impacts could include: aqueous or solid waste streams or air emissions, and solid waste streams, unless damaged or off-spec components could be reused or otherwise recycled. Having that information is key to moving to the next step.

That step involves analyzing the information collected to determine whether the most significant impacts identified can be mitigated by setting various targets, goals and objectives for each of them.

As with the previous step, setting goals and objectives is also a time-consuming exercise, but one that also pays off well as an investment for the organization. With this information in hand, the Iteam should then have what it needs to begin crafting the ISO procedures to address the significant impacts.

At this juncture, the organization should be well on its way in putting together the framework of its EMS. At this point also, if the organization has not yet decided, management should give serious consideration to utilizing some outside help, unless they are confident they can proceed to final implementation and prepare for a certification audit by an outside registrar.

For one organization currently undergoing ISO certification, we were fortunate that they gave us permission to document their experiences - from starting on the Road to ISO to developing their EMS to interviewing and selecting a registrar, culminating in experiencing their first ISO 14001 audit - in a series of articles in a trade newsletter (Maintenance Management).

Those case studies were very useful to portray activities at this facility as it progressed through the ISO process. It is a noteworthy case study approach of what one can expect in pursuit of ISO certification. (If readers are interested, the Publisher will happily provide back issues, based on availability).

In Summary

As has often been said by some ISO proponents about ISO 14001 - it's not so bad, at least, not that bad as some folks may perceive, provided that one doesn't make it to be more than it really is, or feels intimidated by it.

What ISO is though, is hard work, knowledgeable people, competent ISO expertise, whether internal or imported, and constant re-evaluation to get the pieces down RIGHT so that the program can get OFF the drawing board.

And if we keep in this thought process, and view ISO 14001 requirements and EMS elements as a blueprint, the idea is that if you can read it, you can build it.

The key to an effective and workable ISO 14001 program is getting this blueprint designed so that it is easy to follow, and not obscured by extraneous details. Save some of the detail for subsequent revisions, or in ISO-speak, continual improvement.