Show Me the "Shall"

SRI does LEED certification

2009-09-26T05:23:00.000-07:00

SRI is a registrar I do contract auditing for. They register to ISO 14001, OHSAS 18001, ISO 9001, and many more. They are a known leader in the industry for customer service and bringing value to the certification process. They now have a contract with LEED Green Building Rating Systems. Read more in this news release from LEED GBRS.

Document Dilemmas Part 2: The Ultimate Document Smack Down!!!

2009-08-19T23:07:00.001-07:00

For years, I have been telling folks that when it comes to system documentation, less is better. The standard requires the creation of documentation to communicate ideas to the organization in a way that will enhance their understanding of what they need to do to meet the policy commitments. In English, that means that you use documents to tell people what they need to do to comply, improve and prevent pollution.

Naturally these documents need to be tailored to the audience who needs to read them. Unfortunately, to many folks with document creation power focus is on quantity rather than quality - and if it confuses the reader, that's all to the good, especially if the reader is an auditor! I guess the hope is they will go "snowblind" from the blizzard of paperwork and be unable to spot any flaws. BTW, this never works: Tomes do not intimidate auditors: curling up with a nice 1000-page manual and a couple of red pens is considered a good "beach blanket read."

Multi-volume manuals and 25-page SOPs do, however, tend to incite plenty of ire from busy co-workers who must, at best, sign a sheet saying they read them, and, at worst, actually slog through all the material. In case you are missing the point, this is not a good way to convince others to "buy into" the system. You end up with a massive failure to accomplish a key requirement in element 4.4.3 - internal communication. After all, what good is all your documentation if it is more confusing than the poorly translated instructions on your set of chopsticks?

Another inherent problem is that, just like fuzzy, little bunnies, documents have the nasty habit of begetting even more documents, so that eventually, you end up with a red tape nightmare; a labyrinth of paperwork so arcane that even the creators can't find what they need.

Once they have reached this point, most folks throw up their hands, and say that their system is a worthless exercise in bureaucratic BS, which is really unfair because they have created their own monster. The standard very purposefully does not prescribe the format or content of system documentation. This means you are free to improvise to your heart's content.

But as old Billy S. once penned, "Ay, there's the rub." In our quest to find perfection, we often blindly grope for a path forward, and once we find it, we put too much faith in what has already been done, rather than trust in our own ability to innovate. Thus, tradition is born, which is regrettable, since continual improvement and tradition have very little in common.

I know it’s a radical concept, but what if documents could explain everything in one page? What if simple symbols and colors could be used to communicate complex concepts across language and cultural barriers? Well, I'd like to introduce you to some excellent pretenders to the throne so long held by manuals and procedure: signs and forms.

Since it seems like everywhere I go North America, wrestling matches are always available on TV, especially when I only have 6 channels to choose from, I thought I'd use it as a backdrop for my efforts to convince you to give the idea of nontraditional documents a chance. Plus, I had a lot of fun writing it this way. So grab a six-pack and enjoy!

…Hooked On Phonics ad ends...

ANNOUNCER #1: Welcome to the Ultimate Document Smack Down. Tonight, we are here in fabulous "Sin City" to witness what is being called the greatest matchup in Smack Down history. Who will take the coveted prize title of "Most Useful Documents," and who will walk away in shame? In a never-before-seen contest, the lightweight underdogs are challenging the undisputed heavyweight champions in this unprecedented tag-team event.

ANNOUNCER #2: Pinch me, Ted, 'cause I must be dreamin'. The crowd here is incredible!! Fans have been waiting for this contest for years.

TED: That's right, Bob! So far, Manual and his teammate S.O.P. have been unbeatable in their weight division. This match gives them a chance to prove what has been assumed for so long: that they are invincible. With the huge size and weight differences, it's hard to believe the challengers have a chance.

BOB: Too true, Ted, but don't underestimate their opponents, Form and Sign. Tonight, the underdogs look lean, mean and ready to steal the scene. The fans certainly love them and they are hungry for that title - Manual and SOP better watch out.

TED: Careful, Bob - don't let the big boys hear you say that. Tonight isn't just about winning - it's about settling a personal score, and Manual and S.O.P. are out for blood. We needed 2 hours just to cover their pre-battle shield banging. They literally filled a tome with trash talk - and we STILL couldn’t understand them!

BOB: Holy Talking Heads, Ted!! It was waaaay to much to repeat here in our pre-match program - I guess to sum it up… well, you would need a Sign or a Form! Now, these two have taken trash talk to a new level.

TED: Ha! Ha! Ha! You betcha, Bob! Sign just held up photos showing him knocking out previous opponents while Form held up a huge likeness of himself with a big check in the box next to the word "Winner."

BOB: Talk about terse, Ted, it doesn't get much clearer than that, does it?

TED: No sir-ee Bob! Their combined message was easy to read: "You're going down!" Speaking of which, the champions have taken the ring to their theme song: "In-A-Gadda-Da-Vida" while we've been talking. In fact, it's been playing since I got here. As you probably noticed, we could easily talk over their welcome, but the contenders are coming in now ...

Music playing ("A little less talk, a lot more action")

and the crowd is -----

…………...Crowd cheering extremely loudly:" RAAAAAUUUUUUGGGGGGGGHHHHHH!!!!!!!!!!!!".............

DING!!! DING!!!! DING!!!!

REFEREE: In the corner to my left: weighing in at a comprehension-defying 338 pages…. He's got something for everyone (whether they need it or not), he's the current, undisputed heavyweight "champeen": Manual the Miiiinnnnnddd Mannnggglerrrrrr!!!!!

And beside him in the clear plastic page protector, stands his loyal comrade. A monster with a brain-numbing 25 competition-weight card-stock pages, all properly stamped, signed and notarized. The scourge of efficiency, the captor of reason: His name is known and feared around the world... S...O...P... the S...O...B!!!

CROWD: Mixed boos and weak cheers

Referee: AAAANNNDDDD… In the corner to my right, barely tipping the wordsmith's scales with only a few letters and symbols, he's a lean, mean communication machine! He's in your face and everywhere he needs to be: Heeeeere's ... Your... Sign!!!

And next to him, his bold brother-in-arms. He may be only a few ounces, but he's locked, loaded and ready to go - instructions and data all rolled up in one! No one can escape his grasp of subject matter. Devilishly precise and accurate as hell: It's Form-Y-Diablo!!!!!

LET'S GET RRRRREADY TO RRRRRRRRRREAD 'EM!!!!!!!!!!!

CROWD GOES WILD!

BOB: We're starting off with Manual and Sign - opposite ends of the spectrum and a tough matchup by anyone's standards...

TED: Oooh!!!! Nice opening move by the Mangler!

BOB: Holy Controlled Documents, Ted!!! It doesn't look good for Sign. Only a few seconds in, and his eyes are glazing over. That's a classic Manual move: He crushes them with mind-numbing detail, and paralyzes them with irrelevant information. "The Mangler" has been an unstoppable force, but I'm not sure if it's skill or just overwhelming bulk. And his methods are so confusing, his opponents can't seem to figure him out before it's too late!

TED: Looks like Sign is shaking it off now - he is unbelievably quick. Notice how he strategically locates himself for maximum impact and perfect communication of his intentions. His flexibility is a serious advantage; Manual looks like he's bound in comparison…

BOB: You ain't kidding, Ted. You really have to wonder how long Manual can stay in active circulation, especially if his handlers start weighing the cost of maintaining his bulk against the value he brings. Notice how we are seeing Manual's complexity and size really work against him here…

TED: It's only been a few minutes and Sign is still fresh as a daisy, but Manual looks like he hasn't been taken off the shelf in years… The trend in this sport seems to be tipping toward the Yoga Master over the weight lifter, but are folks ready for the new standard of power to be lightweight and flexible?

BOB: Well Sign's fans seem to think so: they are holding up... well, "signs"... with the great Ali's motto: "Float like a butterfly, sting like a bee." Holy quick change artist, Ted!!!! Looks like Manual is ready toss his binder rings to his lighter-weight companion, S.O.P. Now we'll see how Sign fares against someone closer to his size.

TED: S.O.P. is much more flexible than Manual, but he is still weighted down by all his pages. And that plastic protector sheet may keep him looking pretty, but it seriously limits his motion. Another potential disadvantage: his formal style is decades old.

BOB: Darn tootin', Ted! He is definitely old school, but the game has changed and so have the fans. Sign has all the glamour without all the accessories weighing him down. His moves are fresh and simple and his easy style has brought a lot of new fans to this sport. From the look of him, he is certainly cheaper to maintain.

TED: They must be putting the savings into marketing because I see his colorful mug posted everywhere! Look at that full body bind, Bob!! It's amazing how he can appear to be in several different places at once! But it looks like SOP's shiny plastic surface is finally starting to get to Sign - he is handing the match over to his partner.

BOB - Holy Kissin' Cousins, Ted!!! Now we're talking a real Smack Down rivalry!

TED: That’s' right. Remember when S.O.P. and Form were teamed up? S.O.P. is still pretty sore about the split. Form claims that he wised up and realized that S.O.P. was really telling everyone the same thing Form was - he was just using more pages to do it. Form said he didn’t need S.O.P., he had his own star power.

BOB: I guess Form's motto is "We don’t need no stinkin' pages." Form is definitely all access -he puts everything up front, holds nothing back and isn't afraid to be easy to read. He lets everyone know exactly what they need to, and that appears to have been the secret to his success.

TED: Bob, some people think that's a disadvantage in this sport, but check out his choke hold on S.O.P. - even though he saw it coming, he wasn't fast enough to avoid Form. Guess he's getting the message now, huh, Bob?

BOB: He sure is Ted, and I think it says "This page intentionally left blank." S.O.P. is reaching for a tag out from his partner, but once again, his weight and protective gear are against him… He can't make it!! He's closing his eyes... he's down for the count!!! It's over!!!!

TED: While we wait for the results, let's hear from our sponsors.

Ads for beer, and a program to teach you how to read 1000 words per minute

BOB: (caught in mid-conversation) …and if I didn’t think we had an upset on our hands, I'd be buying that program right now…

TED: Oh! Ahem… Hey folks!! Well, we're back and the crowd here has been eerily quiet and intense while waiting for the results…

BOB: OK Ted, looks like the judges have reviewed the tape and are ready to announce their decision...

REFEREE: Ladies and gentlemen, the results are in... Your champions this evening, by unanimous vote from our judges… The prize title of "Most Useful Documents" goes to…. FORM AND SIGN!!!!!!!!!

…………...Crowd cheering immensely:" RAAAAAUUUUUUGGGGGGGGHHHHHH!!!!!!!!!!!!".............

Several minutes later…

TED: Well, there you have it folks - a complete upset of the old order. I guess that saves you some money, Bob - now you don't have to buy those reading programs….

BOB: (sarcastically) Ha, ha. Just proves the old saying: "The bigger they are, the harder they fall." By the way, Ted, you owe me $50!

EXTRA! EXTRA! Yours Truly, In the News!

2009-02-04T20:50:00.000-08:00

Dear Constant Reader (and anyone else who accidentally found this site when they misspelled "Show Me the Shell"):

Much to my absolute amazement and shock, I was approached by an online magazine to offer what was termed a "brain dump" about my environmental knowledge. You be the judge about which end it came from.

Anyway, the 1 hour interview resulted in enough information for 3 articles. Many of you who have either heard my "soap box speeches" or have read my rants (loosely termed blog posts) may be surprised, but never fear. They are long articles and, though written with a more serious bent that you may be used to from me, are probably worth checking out, if only for the highly unflattering pictures of yours truly. Plus, the folks at Blue Planet, Green Living are, if I may coin a term, "eco-licious!"

You can find the articles in all their ephemeral online glory, plus a whole bunch of other neat eco stuff, at www.organicgreenandnatural.com

The articles in order are:

Red Tape, Regulations and Environmetnal Crimes

ISO 14001: Comply with Laws, Prevent Pollution, Continually Improve

My 5: Molly Long, A.W.E. Consulting

Enjoy!

Happy 2009!

2009-01-05T20:15:00.000-08:00

I just want to wish everyone who follows "Show Me the Shall" faithfully a Happy New Year!

I sincerely thank you for your readership and would like to let the both of you know that my New Year's resolution is to audit less and blog more!

Please forgive my unforgivable absence, I was on the road auditing non-stop starting in July through December. Not that I could have competed with all the attention given to the election (that's my excuse and I'm stickin' to it) Of course I always have my trusty laptop with me (although, my Sony puts the "rust" in trusty - but, I digress), so it seems like a pretty lame excuse... Of course, I won't let that stop me from whining...

Besides, as any auditor knows, one's creative juices are not exactly flowing after a grueling day of torturing auditees - although the gin and juice is. OK, so it may have inspired Hemigway, but he was in the Florida Keys, which is infinitely more relaxing than some of the places I have been this year. This brings me to my top 12 auditing FUBARs of 2008 - why not 10? 'Cause I can't afford rehab, so this blog is my 12-step program!

12. Auditing on my birthday in northern Minnesota on a record cold day - You betcha!

11. Visiting the Mexican desert in August and getting Montezuma's revenge - Aye papi!

10. Auditing in Phoenix in July - WTF???

9. Traveling to 9 cities in 4 days and crossing every time zone in this beautiful country - Jet lag-schmet lag!

8. Spending all but 17 of the last 100 days of '08 on the road - even my dog doesn't know me anymore...

Yada, yada, yada, wah, wah, wah, so let's skip to number one:

I get a flat tire in the middle of the night on the way home from an audit. I call the emergency roadside assistance service folks who say they'll call back when they find a tow service. An hour passes and absolutely no one has stopped to help. I decide to change it myself (because I am impatient). To my dismay, I discover that the hand-crank jack (sounds naughty, doesn't it?) needs about a foot of clearance, which my sporty little coupe did not have.

At this point, a state trooper pulls up. I immediately drop the lug wrench, put my hands up, and pray he doesn't shoot me, or worse, write me a ticket for speeding (this actually happened to me the last time I broke down in Indiana). To my utter amazement, he helps me. He grabs a good old American car jack from his trunk, gets the tire off and we grab the spare. Sadly, this is where the fairy tale ends: The spare has to be inflated by a cute little compressor that plugs into the cigarette lighter. The compressor works great - if you are a balloon animal artist and not in a big hurry.

Any-who, we call the emergency roadside assistance folks to see if they have any advice on how we can inflate the tire before we grow old and die. I hand the phone to the officer so he can get the skinny. They have no answers, they also tell him that no wreckers are available and end by recommending he call the police for help.

PRICELESS!

My hubby had to drive down and rescue me.

All in all it wasn't a bad year, but I wish everyone a better 2009!

Document Dilemmas Part 1: To Control or Not to Control...

2008-08-13T08:51:00.000-07:00

...Ahh, but this is really the question: "Do I have to control all my EMS documents?"

If I had a dime for every time I heard it, I might be able to buy a gallon of gas!

This question reminds me of a nonsense riddle my grandfather, Scoop, used to tell: "What's the difference between an orange?"

And, no, I didn't forget the "and what" part...

Done scratching your head?

The correct answer, according to Scoop, is: "It must be a bicycle because a vest doesn't have any arms." Yeah, grandpa was funny like that, and, come to think of it, this traumatic childhood memory probably goes a long way toward explaining why I drink so much now...

Nah... I drink because I audit!

Anyway, this riddle is obviously absurd, and can only result in an absurd answer. Not surprisingly, it has a lot in common with that first question about document control. (Yes, there was a point to this blog besides a stroll down memory lane.)

The standard is actually very clear about document control (I know, I was shocked too). It's right there in the first sentence of element 4.4.5: "Documents required by the EMS and by this International Standard SHALL be controlled."

Not much wiggle room there... But just in case there is still confusion, let's break this high-falutin' language down into what I like to call "Okie-speak" (in other words, the no-BS version):

If you create, have or use a document, ANY document, you gotta control it.

------ COMMENTS FROM THE PEANUT GALLERY ------

GASP!!!***SPLUTTER*** ##CHOKE## ----WHEEZE--- &^%$%#@*!?

Surely she doesn't mean EVERY document! Why, that would be impossible! She's describing a nightmare world!!! What a crackpot!!

She is obviously clueless about the extreme difficulty we have in controlling the few, elite documents that we have chosen for such a high honor! This is outrageous!

I knew it: bloggers can't be trusted, there is no accountability. She can just say anything she wants!!!! This is utter horsesh--

...

Sorry, I stepped away for a second - had to freshen my drink. Hopefully you did too - after all those peanuts, I bet you're thirsty!. OK, let's continue down this path of "utter madness."

Maybe you have nowhere else to go and nothing else to do, or maybe you are tipsy enough not to be offended by my extraordinary philosophy on document control. Whatever the reasons you have stuck with me, you may nonetheless still be skeptical. Good for you, you're still reasoning - that means you can't possibly have alcohol poisoning! But wipe the drool off your chin and rest (hopefully in an upright position) assured that I am not alone in this interpretation. See TC 207 COI 99-03.A7.

Had too many Harvey Wallbangers or Moscow Mules to remember what the #$%& TC 207 is? read Dr. Strangeaudit... to find out more.

Believe me, when I was an ISO newbie back in the day (well after Scoop and well before auditing), I felt that document control did nothing but create a red tape nightmare. This philosophy was based in my gripe that I had enough worries what with the EPA breathing down my neck, and all the laws I had to follow, etc., etc, wah, wah, wah.

No amount of whining can change the fact that document control is an essential key in effective business management, regardless of the type of system. But no matter whom I talk to, it seems that the number one reason people don't want to control a document is because...

\/\/\/\/\/\/ DRUM ROLL PLEASE \/\/\/\/\/\/

IT'S A ROYAL PAIN IN THE BUTT!!!!

But after hundreds of audits, and more than a few attempts to revamp inherited systems, I can clearly see the root cause of the problem, and it ain't the standard folks. Just like Charlton Heston said in Soylent Green: "It's people!"

The standard requires very simple controls. WE create these document control nightmares ourselves - Freud would have a field day with us on this one!

Most document control methods are overly complex and, in reality, more an attempt to create a loophole for document control rather than to actually control a document. To read more on this fascinating (and probably highly inflammatory) subject, check out the next installment in the Document Dilemmas series - Ultimate Document Smack Down!!!

But this post still needs some perspective, some seasoning, or as Emeril might say, some BAM! So here comes the heat - you may want to get out of the proverbial kitchen here, unless, like Hillary Clinton, you are very comfortable there.

For the quality gurus out there who stumbled across this blog while surfing for S&M sites, think of it this way: You wouldn't use an uncalibrated piece of equipment to collect data about the management system - you're certainly not allowed to by the standard - it might help you to imagine the standard wearing a lot of shiny, black leather and carrying a whip. So, think of document control as a form of calibration. You can't use an uncontrolled (uncalibrated) document. And if you did, you would get a spanking for being naughty (and not just because you like it).

Since environmental folks surf for bestiality sites (it's more "natural"), they wouldn't see this blog unless I renamed it "Show Me the Sheep" or something. But even if they did, the above example wouldn't register with most of them who usually aren't as well-trained (I'm not even sure most of them are potty trained) in the finer points of calibration. I am speaking from experience (ESPECIALLY the potty trained part).

But that's OK. I just pull on my Depends and remember that the primary purpose of document control is to ensure everyone has access to current, consistent and accurate information. So here's an example the "bunny huggers" can understand: If you control the procedure for hazardous waste management so that it gets revised when the accumulation time limit changes from 180 days to 90 days, you won't have to trade cigarettes with your cell mate to get your diapers.

OK, perhaps the spiciness has left a bad taste in your mouth. Let's switch gears. It's late as I finish this up, last call has come and gone, the kitchen's closed, and I'm in the mood for some warm milk, cookies and a nice bedtime story. So here goes...

Yes, Virginia, there is a Santa, and yes, you must control all your documents - even your Christmas wish list. Otherwise, Santa might leave you a door mouse instead of a doll house because he didn't know which revision was correct.

Let's stop here and continue the story another night...

Till then, sleep tight and don't let the auditors bite....

Bizzare Audit Experiences

2008-05-30T12:11:00.000-07:00

I have been asked many times what is my strangest auditing experience. I have really had too many to pick one that stands above all others, but here a some of the weirdest by category:

Animal Encounters:

"Nice doggy!": I was bitten by a junkyard dog while trying to take samples based on a complaint that the owner was dumping oil (at a junkyard - imagine that!). Once the incident was reported, the owner reported the dog missing for almost all of the 2-week rabies observation period. It looked like I was going to have to get the dreaded series of shots in the stomach, until the dog miraculously "reappeared" on the last day. Whew! But they don't call me "Mad Dog Molly" for nothing!

"The Stress Musta Got to 'Em":

There is nothing quite like the special ambiance of an emergency room for a closing meeting. My client was having dizzy spells and was uncontrollably nauseous, which is not necessarily abnormal at a closing meeting, but we did think this case was serious enough to go to the hospital. Fortunately he got better, and to this day claims it was NOT the audit, but a temporary loss of equilibrium in his ear after a cross-country flight.

"War" stories are sometimes an excellent way to encourage a client to open up and relax, but ghost stories? One client explained to me that he talks to ghosts that live on the other side of his backyard fence, and they tell him what to do. What can you do but nod your head, smile and try not to make any sudden movements?

Lovely Weather We're Having:

Having 3 tornado warnings in one afternoon was an excellent chance to test the effectiveness of emergency preparedness and response procedures at one organization. Plus, I had a ready-made pool of interviewees trapped there with me. Bonus! Hey, just like showbiz: the audit must go on!

Unfriendly Fire:

As a rookie park ranger (19 years old), I was on patrol, when my veteran partner spotted someone with beer on the beach (which wasn't allowed), so he let me out to write my first ticket. While I was busily trying to figure out how to fill out the form, I was oblivious to everything else, including my perp, who was standing between his car door and the interior of the vehicle. My partner came up behind him, and grabbed the billy club he had been reaching for, brought it up and said" What's this?" I sure learned some important observation skills that day...

...and the "most evil" award goes to this one:

When I was a hazardous waste inspector for the Indiana Department of Environmental Management, I was involved in a case where the owner of a plating company was trying to sell off and/or dispose of all his chemicals so he could skip town. I got involved after the city shut off the company's sewer access and called IDEM in to investigate. The case ultimately wound up with the federal EPA. If it were a Master Card ad, it would go like this:

Fines for illegally discharging your untreated plating solution to the sewer: $5000.
Fines for illegally burning your hazardous waste in the parking lot: $25,000.
Getting ten years in the federal pen for trying to sell your polluted property to the city for use as a youth center: Priceless!

Time After Time - Audit Planning Follies Part 2

2008-05-30T10:50:00.000-07:00

When it comes to figuring out how often and how many (audits, not adult beverages), it is helpful to remember that this not a ritual you do to fend off evil spirits, like vampires (and/or auditors).

Unlike rituals - stabbing voodoo dolls, sacrificing virgins (auditors) or bouts of heavy drinking - internal audits give you measurable data about environmental performance.

Ok, ok, I had you until that last part where I started to sound like a textbook. To clear up any confusion, here’s how Huggy Bear would say it: “Word on the street is, audits tell you what’s goin’ down!”

That’s right, internal audits enable the lonely, red-headed step-child environmental manager (no, a longer title does NOT equal more pay) to get in the loop and find out what’s really going on outside their dark little corner of the office, otherwise known as the broom closet.

What may be the most upsetting to some is that without a required number of audits, it is nearly impossible to plan an avoidance strategy, not that folks won’t still try. Here’s a good example: “If there is no requirement about how often you must audit, is auditing the entire system once every three years often enough?”

Geez! Don’t strain yourself! No, this would not be acceptable. You would fail to meet the requirement to base planning on previous results and environmental importance, not to mention it’s just silly! Audits are your window on the world; do you really want to fly blind for 3 years?

Avoidance strategies like this reflect a failure to see value in auditing. If auditing is something that is done only under extreme duress, you are missing the point of having an EMS. These attempts to side-step "extra work" may also reveal a fear of finding out that things really aren’t working and then having to pass that information along to managers. Ignorance is bliss, right?

I know it’s scary to show your soft underbelly to managers, but if environmental performance equals your personal performance as EMR, you have MUCH bigger problems (See “Taming Your Inner Scapegoat - An Owner’s Manual for Environmental Professionals” – coming soon!)

Remember, EMS is top-down: the buck stops with top management and they drive the system (not the EMR), so if something is not working because of inadequate resources, they are required to provide them. Audit data helps to create an accurate picture of performance; one that you show to your managers so you can get the resources you need: i.e., money, people, cash, equipment, $$$$, time, bucks, training, money, money, money). In other words, audit data is a lot like the PIN to your ATM card: you gotta have it before you can get the dough (or d‘oh!)

You know the old phrase "Money talks..."? Well, you want to make sure your audit data isn't the equivalent of the second half of that famous saying.

So hopefully now you understand that audit data are your "friends." But you may still be asking how audit frequency comes into play.

MULTIPLE-CHOICE QUIZ

Do you want your audit data to show managers:

a) A one-time snapshot?

b) Trends that have developed over time?

If your answer was “b,” you get 1000 points on the EMS-O-Meter toward expert-EMR status. Congratulations! You know that the messenger relaying tomorrow’s potential problems is better off than the bearer of yesterday’s bad news.

As I have said before, the standard intends for you to do internal audits whenever you need the feedback they provide. So now that you know how to schedule audits, the trick is getting them done… AND getting them done right!! (See “Bad Audits and the Auditors Who Love Them” – coming soon!)

To Everything, There is a Season... Audit Planning Follies Part 1

2008-05-21T14:26:00.000-07:00

Do I have to audit all elements of the standard within a year?

What the $^&@*! is a "full cycle" of audits? (See “EMS Registration: The Road to Becoming ‘Certifiable’” – coming soon!)

Will an audit a day keep the registrar away?

These are the questions that keep environmental managers up at night… or at least the night before their registration audit.

Well, let’s see: Element 4.5.5 requires audits to be conducted at “planned intervals,” whatever that means... So a simple schedule showing I audited all the elements in a year should work…

But… wait a minute... What’s this gobble-de-gook in paragraph 2: “Audit programme(s) shall be planned, established, implemented and maintained by the organization, taking into consideration the environmental importance of the operation(s) concerned and the results of previous audits.”??? Huh??? Why can’t they just say what they mean??!!!!!!

What, you want more clarification? Well, alrighty then. How about our good friend (and would-be rapper) TC 207? This roundabout requirement is mirrored - in two-part harmony no less - by COIs 02-03.A1 and 02-03.A2. After reading them, I promise, everything will be clear… as mud.

Don't know what a TC 207 COI is? See "Dr Strangeaudit or: How I Learned to Stop Worrying and Read the COIs."

Still itching for a numbers fix? I’ll try to explain in plain English: You audit when you need to.

It all boils down to that pesky 25-cent phrase: “planned intervals,” which miserably failed to clarify equally vague “periodically” used in the 1996 standard.

So is an interval the same as a “period”? If yes, then what’s a "period"? Is there a standard accepted timeframe that any auditor (no matter how dense) can recognize as a "period"? Whoah there! All this talk about periods is enough to give anyone PMS! To quote Foghorn Leghorn:: “I gotta straighten this lad out; thing like this could warp his mind for life.”

Look, take some ibuprofen, dry your eyes and cheer up. The "party animals" who went to the TC 207 site and read the COIs already know that there is no bare minimum number of audits you can “get away with.” Yep, that’s right. Playing dodge ball around an arbitrary number is not an option here. But there is still a silver lining: in a freak accident of common sense, the standard writers decided to require you to base your audit needs on:

1. What is important to your organization (NOT your registrar auditor), and

2. What has been a problem in the past

This means you focus on your problem areas, both actual and potential. Let’s face it: in the world of environmental management, things are constantly changing, and usually not for the better. Controls seem to fail when it’s most inconvenient, and even relatively good days still have nagging glitches. Then, there are always nasty surprises like mystery drums left by naughty “elves” in the middle of the night. Wouldn’t it be great to catch the problems before they blew up in your face, instead of being constantly blind-sided?

Internal audits help you do this because (if you do them right, and look beyond the "safe zones" of what's already working) they give you consistent, accurate and regular data about how your attempts at environmental control are performing, so you can quickly respond to small problems before they get out of hand. If you do enough good audits of the right things, they might even help you see a problem before it happens and prevent it!! You move from REactive to PROactive.

But I still hear whining: “That doesn’t answer the question how often and how many! Give us a number, we just want a number, surely there must be a number?!!!! WAAAAHHHH!!!!”

Well, just like other addicts, the whiners can’t help it. They have been brainwashed and need their number fix. There are lots of meaningless and arbitrary numbers out there - in permits, in regulations, or (if you really screw up) on your prison-issued clothing. And really, we are all in the same boat with the whiners because, even though enforcement of these numbers is capricious and inconsistent, we all want to believe that, if we meet the numbers, or get under or around them, everything is ok, even when it really isn’t. The reality is more like Lucy swiping the football out from under Charlie Brown – as soon as you are convinced it’s OK, the game changes.

Without our numbers, we often feel like a blind person trying to climb Mount Everest. But you still have “Sherpas” to guide you through this audit scheduling wilderness. You want numbers? Here are 5 things to consider when planning your audits:

1. Applicable legal requirements

2. Significant aspects

3. Corrective and preventative actions

4. Objectives and targets and

5. COMMON SENSE!

Numbers 1-4 are indicators of environmental performance, so they should be audited regularly; how regularly depends on number 5. The EMS does not exist in a vacuum, and you should always listen to your inner reason!

Objectives, Targets and Bullseyes

2008-04-02T21:35:00.000-07:00

...And the comments just keep rolling in - I feel so loved!

Someone has asked what the difference between an objective and target is. A lot of people think there isn't any difference, but there is, and it is important to understand it because objectives and targets are a powerful tool for demonstrating continual improvement.

Both of these terms are specifically defined in the standard in Section 3 (Terms and Definitions) 3.9 and 3.11, which means they don't want you to use the dictionary version. Although the standard writers probably thought they made it crystal clear, you are not alone in asking: "What the #$!@" do they mean?"

A common explanation is that an objective is an overall goal or "umbrella" description of a goal whereas the target is more specific and must be met as part of the larger goal.

...zzzhnh Wha...?? Whoa - I just fell asleep typing that!!!

This reminds me of something mildly hilarious: When asked why the ISO 14001 standard wasn't written more clearly, my instructor answered that it was difficult even for college undergraduates to understand because it was written very elegantly to the "17th-grade level." Folks, I can't make up stuff this ridiculous.

Although mere baccalaureates (I mean, 16th graders) cannot reasonably be expected to attain this lofty reading comprehension level, the concept of objectives and targets could easily be explained to a tipsy barfly with a beer in one hand and a crooked plastic dart in the other.

Think of the type of dart game (301, cricket) as the "objective," and the various numbers on the dartboard, including the bullseye, as the "targets." In the game, hitting individual targets measures progress toward reaching the overall goal: winning. Without both the objective and the targets defined, you might as well throw darts at anything or anyone, which I think we can all agree would not clearly demonstrate continual improvement, even if they were thrown by someone with a PhD.

The standard requires programs be defined to achieve objectives and targets. So I'll take this example one step further (too far?) and define a "program": the barfly (responsibility) must use the darts (means) to finish the game before he passes out (timeframe).

And just because I can, I'm going to go over the proverbial cliff with this example: In 4.5.1, the standard requires calibrated/verified equipment to monitor objectives and targets. This is because the data must be not only accurate, but consistent, reliable and repeatable. So, to return to the example: if the "equipment" is a drunk person using worn out bar darts, I wouldn't bet on a winning streak. In other words, "GIGO" applies.

There are lots of myths about how objectives must be set and what they must include. For more information on objectives and targets, see the following COIs: (click on the link under "Faves," or if you don't know what COIs are, click here)

99-03.A4

97-05.A1.R99-06

07-08.A1

07-08.A2

Maaaa! Do I Have To?

2008-04-02T15:26:00.000-07:00

Some bold soul has asked one of the most common questions out there: "Is it mandatory to have one or more significant aspects to be registered?" Huzzah!!! My first comment. I'm so excited...

The essential answer is: YES!

Now, you may feel a little sheepish telling someone, "Well, this blogger said to do it..." Baaah humbug! Fortunately, you don't have to depend on an opinion-based blog to get the answer because the standard writers (TC 207) and the registrar oversight body (ANAB) have kindly provided the "official" answer to this question. To quote Mr. Burns: "Eh-eh-xcellent!"

There are actually 2 different places to find the answer, although only one really applies if you are seeking registration.

1. Our TC 207 friends answered almost the exact same question in COI 04-03.A1. Unfortunately, their publishing skills do not appear to extend much beyond stone carving because you cannot directly link to this question online, but you can access the COI document that contains it here, or by clicking on the link provided under "Faves." Hint: it's in the 2004 version.

For more information on TC 207 COIs see the following blogs: "How I learned to Stop Worrying..." and "The ABCs of COIs"

2. TC 207 gets you most of the way there, but those competing for "registration gold" must play by the rules - in this case, ANAB's Accreditation Rules. This group of sages has at least a minimal grasp of "that new-fangled internet thingy," and you can directly access Accreditation Rule #13 online.

For that ANAB history buff out there (you know who you are), AR 13 supersedes Advisory 20. More importantly, it incorporates the TC 207 COI mentioned above and adds some extra ANAB icing, which spectacularly fails to make this topic any less dry. So, grab something to wash this down (it should be at least 80 proof), and I'll give you the "CliffsNotes" version - there is no movie version (thank God!!)

AR 13 essentially says: If you don't have any significant aspects, you won't have a system that can be registered because you WON'T have to do..., well, pretty much anything and everything that would show an auditor you have a system in place. That's because key elements all tie back to SIGNIFICANT aspects; heavy-hitters like: objectives and targets, training, communication, operational control and monitoring and measurement. You don't need to do this stuff for INsignificant aspects, so without any significant aspects, you basically don't have a reason for a system.

You just snorted your drink through your nose, didn't you? I can hear the choking and spluttering from here. In the immortal words of George Carlin: "Calm down, have some dip." OK, so you've changed your shirt, refreshed your drink, and taken several deep breaths. You are dry, relaxed, and best of all, armed with new (albeit painful) knowledge: You must have at least one (1) significant aspect to get registered. Whew!

But this begs a second question (so take a big steadying gulp and swallow it before reading on):

Why put a whole EMS program in place around 1 or 2 aspects? And even if you still see value in a severely limited scope, why register such a system? It's like throwing a big party and not inviting anyone. OK, registration is nothing at all like a party, except for possibly the excessive drinking, hangovers, and morning-after regrets.

For more information about this endlessly fascinating topic, see "Covering Your Aspects" - coming soon.

The ABCs of COIs

2008-03-13T15:54:00.000-07:00

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

2008-03-13T09:08:00.000-07:00

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"

2008-03-12T13:11:00.001-07:00

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