A
Sustainable Approach To Changing Market Conditions With the Management
System |
8.27.04 |
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Rebecca Pehler, HSE MS Consultant,
Webb, Murray, and Associates, Inc.
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Sustainability and in many cases the license to operate for business is defined
by its Health, Safety, and Environmental (HSE) commitment and policy. Security
is a factor that is included in on these considerations (HSSE) due to heightened
awareness of global terrorist activity.
By having a Management System (MS) in place, these HSE issues; as well as
security, are evaluated and worked on a more sustainable basis by looking at
both the combined and individual work flows of business. In other words,
"This is who we are and this is how we work". Work flow is defined as
the inputs and outputs of the work function or job:
- Input: Who and what is needed to do the job.
- Output: Who and what relies on the product or service resulting from doing
the job. Are customers being satisfied when the job is done?
Sustainability is the action of business in response to HSE issues that
affect employees, contractors, stakeholders, and the surrounding community. In
other words, present day operations of business do not hamper future
performance. Some elements of sustainability include:
- Economic: Business stays profitable in supporting the generation of
jobs and technology.
- Social: Assuring the safety and working conditions of employees
that help and sustain the job and business.
- Environmental: having in place a MS. Having an increased awareness
of the existing controls of the job that assist in preventing environmental
impact.
- Product Stewardship: Responsible use of products. Minimizing waste.
Reducing energy consumption.
Work flow processes in a MS are maintained by:
- Awareness of the work flow’s impacts that have both an actual and
potential to adversely impact or benefit the environment. By knowing this
information the business can better formulate an environmental policy or HSE
policy that identifies priority items to address so that objectives and
targets are met. Also, this information can be used on adequately
positioning the business to respond to security concerns.
- Environmental or health and safety issue of corrective action to
solve work flow issues of nonconformance. Assurance that there are
procedures or methods in place to:
- Identify the issue of nonconformance in the work flow.
- Be aware of and implement appropriate corrective action. Once
corrective action is undertaken, all related procedures and documents
are updated.
- Assure that quality control systems are in place. Are the controls and
procedures adequate to insure that these problems of nonconformance do
not arise again?
- Are security measures and emergency response in place to adequately
respond if needed?
- Having sufficient resources to maintain the work flow in the areas of
implementation, monitoring and measuring, tracking, and frequent specified
management reviews.
- Self-assessment, resolution and subsequent tracking of environmental or
health & safety issues. Designating individual responsibilities and data
storage systems.
- Being aware and maintaining communication with stakeholders concerning the
inputs and outputs of a specific work flow. In other words, knowing who is
responsible for what, who needs what, and whom does the finished work flow
go to.
A world-wide standard; ISO 14001, exists that defines issues of environmental
work flow in business. ISO 14001 defines requirements of emergency response to
and preparing for environmental incidents for a business. The ISO 14001 standard
does not cover health & safety work flow requirements. Implementation,
monitoring, measurement, corrective action, procedures, standards and management
review are just some of the categories covered by ISO 14001 as applied to
environmental issues of business. Application of ISO 14001 is not limited to the
petrochemical business, but can be found in other areas such as: automotive,
municipal services, schools, retail stores, and hospitals. The value of the ISO
14001 standards is that it focuses on environmental impact awareness of work
flow; not job function, as a part of business.
An example of Health, Safety, and Security requirements for a MS is covered
by American Chemistry Council’s (ACC) Responsible Care. Responsible Care takes
into account input from regulators, customers, the public, and other
stakeholders that are not addressed completely in the ISO 14001 standard.
However, the environmental components of work flow within the business are not
addressed. Sustainability is not fully met. ACC addresses this issue by
broadening their management system standard to include the environmental
components. This management system standard is called RC 14001. From a business
point of view, by integrating environmental into Health, Safety, and Security
management, everyday business decisions will be driven by that. Additional
benefits include and are not limited to: improved risk analysis, consistency of
documentation, and minimization of business environmental impact.
When deciding the extent of coverage for a business MS there are several
choices for the business to review. The extent of coverage for the MS is
influenced by:
- Management commitment to having an MS in place? Will it be supported?
- If so, will the MS core center around an environmental standard or one
that applies to Health, Safety and Security?
- If the decision is to have an integrated Health, Safety, Security, and
Environmental MS, then thought must be given as to where there is overlap of
requirements from the standards. This should be done in the planning stages
with consideration of how this will affect maintenance of the MS.
Traditionally, jobs are viewed as work functions within business. A work
function is defined as a specific task that is required to make business
operate. Overall business has multiple work functions that correlate business
objectives and targets. Issues of adjusting objectives and targets in response
to changing business conditions sometime lack consistency and focus. The
offshoot from this would be an effect on compliance, customer satisfaction,
profitability, and protection of the environment. Each employee or participant
in a business has the potential to effect the environment in his or her
day-to-day job function. This requires that business assures that the employee
or participant has sufficient awareness and training on the job function so that
objectives and targets can be met. Overall, business is more organized in
coordinating work flows so that objectives and targets can be met consistently.
Overall the MS has components of:
- Objective and Target Setting
- Risk Management
- Policies, Plans, and Setting of the Business Direction
- Organization and Resources
- Standards and Procedures
- Self-assessment or Audits
- Implementation, Monitoring and Corrective Action
- Security
- Management Review
Collectively, these components represent the statement, “This is who we are
and this is how we work”. These are the core components of a business that
should be defined and in place; whether petrochemical, paper, or retail for
example. The individual and collective work flows of a business are covered by
these core components. One can also look at this being the controls of the MS.
Controls of the MS describe the collective work flows and objectives of the
business while simultaneously responding to changes in both the business and
regulatory climates. The efficacy of controls should be the focus of an
organized system of self-audits within the business. All of this should be
documented in a manual for purposes of communication and awareness to all
relevant stakeholders of the business. The components of the MS, or controls,
also provide value to management of the business in monitoring and measuring
HSSE performance and achieving continuous improvement.
Some Key Elements to Have In Place with MS Controls:
- Objective and Target Setting: Have a business Commitment &
Policy statement supported by management. The Commitment & Policy
statement assure the presence of:
- Management, employee, contractor and other business participant
support of HSE.
- Setting of Objectives & Targets that are representative of the
business goal of HSE continuous improvement. These are reviewed annually
in order to ascertain if they are representative of business operations.
- An awareness by management, employees, contractors and other business
participants (stakeholders) to minimize environmental impacts of work
flow. This awareness covers both actual and potential environmental
impact of the work flow. A means of self assessment is required to
support this.
- A program in place to monitor, measure, and communicate HSE issues of
the business. A means of self assessment is required to support this.
- Assure that stakeholders have means to communicate HSE concerns.
Business management reviews these concerns periodically.
- Risk Management: Awareness of both the actual and potential impacts
of the work flow. What are the acceptable levels of risk for the business?
How will they be measured and what will be the approach to mitigation?
- Policies, Plans, and Setting of the Business Direction: Setting of
responsibilities, accountabilities, and authorities of work flows.
Documentation and communication of this information are important.
- Organization and Resources: Documentation and communication of
responsibilities, accountabilities and authorities of work flows. Ensure
that competencies of the work flow are maintained by training.
Responsibilities are defined in work flow for those that are not employees
of the business.
- Standards and Procedures: Performance is reviewed on a specified
frequency for purposes of assurance that standard (internal and external)
requirements are being met. Assurance that key procedures are based on
performance and target setting of the business. A document control system is
in place. Procedures are reviewed and updated on a set frequency. Obsolete
procedures are eliminated.
- Self-assessments or Audits: Relate nonconformance of the business
controls to gaps to root causes of: communication, procedures, training, and
maintenance of equipment, record keeping, and self-assessment.
- Implementation, Monitoring and Corrective Action: Are there repeat
findings of non-conformance? Is performance reviewed on a set frequency? Is
calibration on a set frequency and documented?
- Management Review: Assess performance by review of audits,
corrective action, meeting objectives and targets. Also review input of
stakeholders (employees, non-employees, community, and regulatory concerns)
which are included in the business target and setting of objectives.
Steps To Take In Setting Up An MS:
I. Management buy-in and promotion:
- Define the key components of the MS. Examples include but
are not limited to: organization and responsibilities, employee
participation and ownership, auditing, monitoring/measurement, security
concerns, and reviews by management.
- Communication: Message of commitment and a requirement for
awareness, participation, and understanding of the MS components as
specified in the manual. Management designates a team that is responsible
for implementation, monitoring, performance evaluation, and management
review. Appropriate authorities are defined for each member of the team.
- Compliance: Decide the monitoring and measuring of key
performance statistics of the business which must be followed and their
frequency of review. Decide how this is to be incorporated into corrective
and preventative action.
- Objective and Target Setting: Take inputs from the following
and collectively set for the business on an annual basis:
- Assessment of environmental impacts
- Compliance with regulations
- Compliance with work flow standards (for example RC 14001)
- Waste reduction
- Security standards for business operations.
II. Identification of Environmental Impacts
- Define the type of environmental impact and area or service
affected. Identify if any security concerns.
- Communicate and document the significance of the impact
(low, medium or high).
- Compliance: Identify the controls in place to limit the
environmental impact.
- Objective and Target Setting: Key environmental impacts
include:
- Emissions to the air.
- Releases to water.
- Waste management.
- Land contamination.
- Use of raw materials and natural resources.
- Surrounding community environmental issues.
- Use information collected to make a Policy statement for the business.
III. Set Policy statement for the business.
- Defined by management of the business to:
- Comply with health, safety, and environmental regulations
- Protect the environment
- Continually improve performance
- Communicate: reviewed on an annual basis by business
management. For maximum effectiveness and buy-in, business management should
make this a partnership with work groups such as the union and contractors,
within the business.
- Compliance: Reviewed and adjusted annually by management in
response to both internal and external business operations. Internal audit
results should have input into this process.
- Objectives and Targets: Include policy statement review in
preparation of the business plan.
IV. Have a business self-assessment and planning that overviews:
- Define and review reporting of environmental or health &
safety performances; as well as security concerns, of previous years. Review
previous objective and target setting and actual performance achieved.
Document successes and failures in relation to meeting the business goals of
continuous improvement of performance.
- Communicate, review, and document management practices and
procedures that succeeded in meeting continuous improvement of performance.
Evaluate input from different departments within the business, customers,
and the surrounding community on business performance. Review existing
procedures of dealing with contracting and procurement to determine their
efficacy on enhancing business performance in addition to potential input to
business security.
- Compliance: The business should:
- Review the existing process to investigate and resolve issues of
noncompliance of the business work flows. Does corrective action work in
a timely manner to identify, review, resolve, and follow-up on the
non-compliance issue?
- Document and communicate responsibilities and accountabilities of work
flows within the business. Define authorities. Establish teams to
implement, maintain, and improve performance of the business.
- Develop and maintain an MS documentation manual that is used as a
central reference for all personnel within the business. In addition to
defining the components of the MS, this manual should contain references
to standards, operating procedures, and work instructions that define
the business.
- Objective and Targets: Are results from corrective action
used as input in order to reflect and respond to changing business
conditions? Is this process documented in the business MS manual? Does the
business have in place a stand-alone document that defines the objectives,
targets, and goals for the business? Is this document located where
personnel can have ready access to it?
V. Implementation
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