Maaaa! Do I Have To?

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

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.