The ABCs of COIs

In the post "Dr. Strangeaudit - or How I Learned to Stop Worrying and Read the COIs" I discussed the joys of exploring TC 207's clarifications of intent (COIs). Better than sex wasn't it - OK, maybe not, but you probably slept almost as well, didn't you? Anyway, maybe you found that reading them from start to finish was a waste of a good cigarette.

The COIs can confuse more than help if read the wrong way. Apparently TC 207 has never heard of a FAQ, so I am working on an index. Meanwhile, below are some (I hope) helpful navigation tips:

A is for "A FAQ would be helpful here." The COIs are in a Q&A format, so rather than reading straight through, it's better to use them as a diagnostic tool. Remember, COIs are specific to the question's context, so don't apply them too broadly. See "F" below if you read the first 2-3 pages and didn't see any Q&A.

B is for "Beginners like FAQs." Each question is numbered - Fabulous! Some questions refer to each other by number - Neato!! The numbers start with the year, older questions first - Brilliant!!! Unfortunately this helps ALMOST NO ONE since there is no index of questions!

C is for "Could we please have a FAQ?!!" The COIs are rolling: those made for the 1996 edition are still valid for the current version (2004), unless removed or revised (which is noted). You have to parse through all the COI documents to see all the questions because there is no comprehensive cross-reference.

D is for "Definitely read this tip." Read the COIs with an objective eye (it helps to be sober). TC 207 makes their own definition for certain words. If not, the rule is to use the most relevant (not common) dictionary meaning. Just like mom always said: "Look it up!"

One important term left to fend for itself is "significant," which can mean different things depending on context. Skewed COI readings have been the downfall of many. Look for a particularly nasty example in a future blog called "Covering your Aspects" - coming soon...

E is for "Everyone with a certified system, take note." COIs don't account for specific accreditation rules and requirements ("We don't need no stinkin' certs!"). If you are a certified system, or plan to register, there may be additional requirements that apply - there certainly are in the "good ol' U.S. of A." So put on your PJs and bop on over to the ANSI-ASQ National Accreditation Board (ANAB) website where you can guarantee another good night's sleep with the "Accreditation Rules" for U.S. certifications.

F is for the grade I would give the COI format. The instructions for submitting a question to TC 207 take up the first 2-3 pages of the COI - scroll past the boilerplate BS for the Q&A. There is no TC 207 "hot-line, " so if you want a different question answered, see the "condensed" instructions for submitting to TC 207 (p.1-3) - just don't hold your breath waiting for the answer! If you get selected, it apparently takes months to respond (so much for instant gratification). You're SOL for any answer unless your question is both carefully crafted and deemed valuable to share - unlike American Idol, really bad questions won't earn you fifteen minutes of fame.

Dr. Strangeaudit or: How I Learned to Stop Worrying and Read the COIs

So, what the #$%@ are COIs?

COIs, or Clarifications of Intent, are written by TC 207.

Well, who the $%&# are they?!

Technical Committee 207 is the International Organization for Standardization (ISO) committee responsible for developing the ISO 14000 series of standards and guidance documents.

In other words, they write the standard you are trying so hard to follow, so when they provide a clarification it is "normative" - sort of like God giving Moses advice on how to apply the 10 commandments. It is the official "intent" of the standard.

Great! So where do we get a hold of these puppies? Click on this link. It takes you to a page listing links to the various COI documents, which you can pull up in MS Word.

Which brings me to an important note: be sure to read the blog titled the "ABCs of COIs"

AUDIT TIP
Remember, COIs are the official "intent" of the standard - a "shall" so to speak. So when Dr. Strangeaudit tells you the standard intends something, it should be in alignment with the COIs. Now you have the power to defend yourself and your program against unreasonable and arbitrary findings and opinions. Woo Hoo! Knowledge truly is power (but be sure to read the "ABCs of COIs" first!!!!).

MORE ABOUT TC 207
Those with keen auditor skills may have noticed that link to the COIs takes you to the American Society for Quality (ASQ) site. TC 207 has their own website (and if you have explored it, give yourself an ISO star) with a pretty good basic FAQ about what ISO 14001 is all about (from the horse's mouth so to speak). What the website does NOT have is a link to the COIs (duh!). It also looks like the site hasn't been updated since maybe 2003. Brilliant!

Anyway, the ASQ site is pretty much the only place to get them, although a Google search for the COIs won't take you directly there.

Intro to "Show me the Shall"

This blog is all about ISO 14001 implementation and auditing, so, there are basically three types of people (or maybe only 3 people period) who might be interested in it:

“ISO fed up with this frigging EMS!” (Embattled EMRs)
“ISO frigging confused about EMS!” (Shell-Shocked Newbies)
“ISO tired of frigging traveling!!” (Road-Weary Auditors)

Even if you are not one of these poor devils, there’s something here for everybody (OK, maybe not normal people): advice on EMS implementation and maintenance, internal/external auditing tips for both parties (how to tell people they have an ugly "baby", AND how to deal with audit results showing that your "baby" is, in fact, ugly) and common sense advice based on "real world" experiences.

The primary purpose of this blog is to explain the “shalls” of the standard in layman's terms, but the ultimate goal is to reveal the great hidden secret behind ISO 14001 --- drum roll please --- there is way more flexibility than you think! I hope the explanations and examples will help your system work for you, instead of the other way around.

This is a place to share experiences, gripes and, of course, audit horror stories - so please feel free to comment! Just remember, the central philosophy is the title of this blog - everything should be geared toward continual improvement of our understanding of the standard (how's that for buzzword bingo?) All advice is based on the "KISS" principal (and if you don't know what KISS means, say "hello" to the root cause of most of your troubles!).

I can’t think of a drier topic than EMS. For example: document contr…YAAWWN!!! – need I say more? Still, I hope to make it a little entertaining (at least not boring), and, of course, enlightening… well, maybe just thought-provoking... Um, how about only mildly upsetting? OK, OK, I’ll shoot for not morally offensive. FINE! Not morally offensive to “everyone.”

This brings us to the only rule I can think of now: Ground Rule #1 Let's keep it fun. No personal attacks and don't take any of this personally. This blog is based on my opinion, and all comments and contributions are just opinions. This is my creative outlet and I do it because "I love." And, (just to throw a movie quote in): "Love means never having to say you're sorry." So everyone put on your "big girl panties" and play nice.

IMPORTANT NOTE: Please make any real-life examples anonymous. We must protect the innocent AND the guilty, like

…well, you know who you are...

For more on who I am, and why I feel even remotely qualified to tell anyone anything about ISO, see my profile or download the pdf.

SHAMELESS PLUG
If you are actually desperate enough to want my consulting or training services, you can call me on my mobile (219.871.9748) or send me an e-mail at mollylong@aweconsulting.biz.

If you are tired of watching YouTube or need another time-wasting diversion, check out my website: www.aweconsulting.biz. You won't win fabulous prizes or become instantly (in)famous, but you can learn more about the standard and A.W.E. Consulting, Inc.

For those of you stalking me, I've just made it easier - now you can follow me on Twitter (ISO14001MEL) - click the link in the right hand column.

Anyway, ISO happy you are reading this and I hope it is helpful!

Happy audit trails!
Molly