Clause 10 Improvement
ISO 9001:2015 Clause 10, Improvement, has three sub-clauses:
This clause requires organizations to determine and identify opportunities for improvement of the EMS. The requirement for continual improvement has been extended to ensure that the suitability and adequacy of the EMS—as well as its effectiveness—are considered in the light of enhanced environmental performance. There are some actions that are required that cover the handling of corrective actions. Firstly organizations need to react to the nonconformities and take action. Secondly, they need to identify whether similar nonconformities exist or could potentially occur. This clause requires organizations to determine and identify opportunities for continual improvement of the EMS. There is a requirement to actively look out for opportunities to improve processes, products or services; particularly with future customer requirements in mind. Some of the factor influencing improvement includes
- Top management commitment to environmental management – setting an environmental vision or corporate policy
- Total involvement of employees – “green” teams are being set up to tackle environmental problems
- Training – employees to be trained in skills that are required to fulfill their environmental responsibilities and achieve their environmental goals
- Green products/process design – designing production processes and products in such a way that the design has a minimal adverse impact on the environment
- Supplier management – environmental performance used as one of the criteria when choosing a supplier
- Measurement – objective measurements established to gauge the level of environmental performance
- Information management – environmental information must satisfy four main criteria, i.e. timelines, accessibility, accuracy, and relevance.
The external factors influencing EMS improvement conforming to the requirements of ISO 14001 are the following:
- opinions and conclusions of interested parties regarding environmental performance together with complaints from the community
- pressure from the competition
- market requirements and customer complaints
- legal requirements on environmental protection
- the possibility of obtaining partial or full non-returnable financial support or subsidies for the EMS improvement
- new legal requirements that come into force
- requirements of administration units
- requirements of certifying bodies
10.2 Nonconformity and corrective action
When a nonconformity occurs, the organization must react to the nonconformity and, take action to control and correct it. It must deal with the consequences, including mitigating adverse environmental impacts. It must evaluate the need for action to eliminate the causes of the nonconformity, in order that it does not recur or occur elsewhere, by reviewing the nonconformity, determining the causes of the nonconformity and determining if similar nonconformities exist, or could potentially occur. It must implement the action needed and review the effectiveness of any corrective action taken. If necessary it must make changes to the environmental management system. Corrective actions shall be appropriate to the significance of the effects of the nonconformities encountered, including the environmental impact. The organization must retain documented information for the evidence of the nature of the nonconformities, any actions taken and the results of any corrective action.
The Standard requires that the organization shall establish and maintain procedures for controlling non-conformities and for taking corrective action to mitigate any impacts caused.No EMS is perfect. You will probably find problems with your system, especially in the beginning through audits, measurement, or other activities. Your EMS will also need to change as your organization changes and grows. When system deficiencies are encountered, your organization will need a process to ensure that:
- problems including nonconformities are investigated;
- root causes are identified;
- corrective actions are identified and implemented; and,
- corrective actions are tracked and documented.
Thus the organization must have the capability of detecting nonconformances and then setting up mechanisms for correcting each nonconformance. Further, it should be able to put into place systems that will prevent a recurrence of the same non-conformance.EMS nonconformities and other system deficiencies should be analyzed to detect patterns or trends. Identifying these trends will allow you to anticipate and prevent future problems. Focus on correcting and preventing problems. This approach is consistent with the continual improvement philosophy. A moment should be taken here to consider what is understood by ‘nonconformance’ because not every organization knows what an environmental non-conformance is. Some time should be spent defining the term ‘environmental non-conformance’ to all interested parties. For example, not following a procedure is an easy non-conformance to identify. However, this is really a management system non-conformance. A true environmental non-conformance could be a cracked bund wall that has not been repaired as programmed – thereby increasing the risk of an environmental incident. The requirement of ISO 14001 goes on to state that any corrective action that is taken shall be appropriate to the magnitude of the problem and commensurate with the environmental impact encountered. This is to ensure that the organization is mindful of that word ‘significance’. Referring to the cracked bund wall above, suppose that it is designed to contain only process waters of low toxicity. Clearly, a similar cracked bund wall intended to contain a cocktail of waste solvents has a much higher priority on the corrective action agenda. Higher priority must also be given to monitoring and maintenance costs than the former bund wall. Therefore the organization is using its finite financial resources in the most effective way.
If your organization has an ISO 9000 management system, you should already have a corrective action process for quality purposes. You can use this as a model for EMS purposes. Small companies might find they can combine their management review and corrective action processes, especially if the same people are involved in both. At the very least, a strong link should exist between the two processes. The amount of planning and documentation needed for corrective actions can vary with the severity of the problem and its potential environmental impacts. Don’t go overboard with bureaucracy, simple methods often work best. Once you document a problem, the organization must be committed to resolving it. Corrective actions should be implemented as quickly as possible. Be sure that your corrective action process specifies responsibilities and schedules. Review your progress regularly and follow up on any deficiencies. Make sure you collect the right data/information to make good decisions. While many corrective actions may be “common sense,” you need to look below the surface to determine why a problem has occurred. Initially, most EMS problems may be identified by your auditors. However, over the long run, most problems and good ideas may come from the people in the shop doing the work. This should be encouraged. Find ways to get employees involved in the system improvement process for example, via suggestion boxes, contests and incentive programs.
Major and Minor Non Conformance
Major and minor nonconformities can differ depending on what sector your organization operates in. Any type of nonconformity may have a greater environmental impact at a nuclear power station than at a car parts retail facility; nonetheless, if you are handed a nonconformity you may fail your 14001:2015 audit, so it is vitally important that you understand the difference. With that in mind, let’s look at some examples of each to help you relate this to your own business and understand how both major and minor nonconformities may manifest in your company. Minor nonconformities (a minor deficiency that does not seriously affect the efficiency of the EMS):
- Let’s say your organization has a process and procedures, but it is discovered during the audit that one person is not using this correctly or at all. This may be raised as a minor nonconformity.
- Your organization keeps maintenance records to prove machinery is maintained. This is generally done, but one or two instances have been missed.
- A procedure exists, but is not found to be accurate and needs an amendment to ensure the process can be followed accurately.
Major nonconformities (a major deficiency that seriously impairs the effectiveness of the EMS):
- The organization has failed to comply with or implement a clause of ISO 14001:2015.
- There is no evidence, or evidence is not substantial enough, of corrective action.
- Procedures are missing.
Minor and major nonconformities can be treated slightly differently, as some minor instances can almost be fixed on the spot. However, a good practice is to use your established corrective action procedure to ensure your nonconformities are treated in the correct way in terms of root cause analysis, monitoring, and prevention of reoccurrence. Remember that clause 10.2 of the 14001:2015 standard specifies how to deal with nonconformity and corrective action, and documenting any changes that may occur in your EMS due to repairing nonconformity falls firmly into that category. So, if you treat the process of repairing a nonconformity as you would with any corrective action, you will have evidence to demonstrate compliance to the auditor if executed correctly. While prevention is better than cure, we understand that in reality there will be instances where we have to fix problems identified by an auditor.
10.3 Continual improvement
The term continual improvement is used to identify the need to systematically improve different processes within the EMS in order to provide improvements overall. It is unreasonable to expect that every process within the EMS will be improving all the time, so continual improvement is used to plan, monitor, and realize improvement in some processes that have been identified for improvement.
The concept of continuous improvement is much misunderstood. An organization may have an objective to reduce its amount of waste to landfill. A target of 50% reduction may have been achieved over a period of some 3 years, a commendable environmental achievement. It could be, however, that to reduce this further (to demonstrate continuous improvement) would not be cost effective, perhaps the law of diminishing returns starts to operate at this level of reduction. The organization may well suffer financially to continue in this direction. The intention of ISO 14001 is to recognize this and really wants the organization to then focus on a different area of improvement. Operational controls will be in place to maintain the reduced waste to landfill quantities. Management can look elsewhere in its processes for improvement. Thus, over a long period of time, the organization can demonstrate improvements, year upon year, although of course, the improvements will be in different areas or departments of the organization. It is achieved by continually evaluating the environmental performance of the EMS against its environmental policies, objectives, and targets for the purpose of identifying opportunities for improvement. And, although we are talking about continuous improvement in terms of reduction of tangible waste or measurable and cost aspects (reduction of the use of electricity, fuel, etc.), continuous improvement in the EMS is allowed. Some organizations have, for example, recognized shortfalls in measurements. Thus an environmental objective could be to improve the accuracy of the data they receive for electrical energy consumption. They may only have a site-wide figure. The objective is to find methods to obtain energy consumption from each piece of plant. They can then focus more easily on the less efficient plant for a replacement for example. Such an environmental objective does in itself not reduce electricity consumption, but the system is improved allowing the possibility of reducing energy use in the future. Overall, the EMS will have been enhanced. One organization may decide that, due to its processes, it cannot detect quickly enough if they are going out of consent with their effluent treatment, resulting in higher effluent treatment charges rather than prosecution from the authorities. An objective would be to investigate methods and or new detection equipment to prevent this from occurring in the future.
While there are many ways that continual improvement can be planned within an EMS, two of the main processes identified in the requirements of ISO 14001 are the use of environmental objectives and risk-based thinking. Through the proper use of these two processes, you can see great benefits from continual improvement in your EMS.
1) Use of Environmental Objective for continual improvement:
Environmental objectives are intended to be planned improvements to your EMS processes, the main contributor to continual improvement. Here is an example of how this might work within an EMS. An office creates an objective to reduce their usage of paper within the office environment, to reduce the need for these natural resources and reduce the recycling requirements created by the paper. A target of 35% reduction within 6 months is set for this objective. A program with the following activities is started to achieve this goal: Force all computers and printers to use double-sided printing within 1 month. Install the software on all computers to better view documents on the screen rather than printing within three months. Install software so that incoming faxes are saved as online PDF documents, which are emailed to the recipient rather than printed for review. Through applying the resources to accomplish this environmental objective, EMS improvement is achieved through fewer natural resources used and less waste being created, even if it is destined for recycling.
2) Use of Risk-based thinking for Continual improvement
Like the use of environmental objectives, the application of risk-based thinking can also improve the processes of the EMS. In ISO 14001:2004 the preventive action process is used when you identify a problem that could occur in a process before it happens. When you identify a problem that could occur and correct the process before the problem can happen, you are once again improving the EMS. In ISO 14001:2015 preventive action has been removed, but the concept of risk-based thinking has been incorporated to identify risks before they happen. Here is an example of how risk-based thinking could work. A wastewater treatment process is tested for chemical composition and treated before release to the municipal sewage system. It is discovered that there is a risk that errors could potentially happen with the treatment. This could lead to legal non-compliance and contamination of the sewage system should the error occur. An investigation into the risk finds that the root cause of this potential problem is that errors could be made with this process due to the manual nature of the treatment, which is dependent on an operator making the correct measurement to treat the wastewater. It is decided to address this risk and action is taken to install a system that performs an automatic chemical composition test and adds the correct amount of treatment to the waste before disposal. This eliminates potential error. Some continual improvement is also seen with the corrective action process; however, the problem has already occurred with corrective action. This is still an improvement, but it occurs after an environmental incident has occurred and is less preferable to identifying the risk and addressing the problem before it happens. It is not necessarily clear from the beginning, but continual improvement is the biggest benefit that you get from implementing a successful EMS. By making improvements, you not only reduce the environmental footprint of your organization, which is good for both your company and the world, but you can also see a financial return on investment from some of these activities. When you reduce the natural resources used, such as the paper reduction initiative mentioned above, you also reduce your costs and improve your bottom line. This is not only a win for the environment but also a win for your company and its future success. Why not use continual improvement to make your organization better and reap the benefits?