A view from the inside

by Suzanne Orme

Successful audits are a win-win for the community and for businesses wanting to prove to themselves and others that they do what they say they do . By examining a business from the inside out an auditor confirms that the company is meeting the expectations of all interested parties.

Let’s think of the analogy of clothing.

When garments are viewed from the outside in there may be a glossy brand image, attractive packaging or convenience features.  Only when the clothes are turned inside out do the seams, patterns and structure become visible and understood.

What you see is the other side of the same thing. The garment hasn’t been deconstructed – just viewed in a different light, in all its reality, worts and all. The strengths and positives are seen and admired – the reinforced seams and new, unfaded materials and the creative effort applied to its design. But a closer look reveals some weaknesses – the fraying hems, broken stitching, worn fabric and repaired holes.

Just like a jumper that looks OK when its being worn, the deterioration of a company’s standards relating to environmental protection are not immediately apparent to key stakeholders – senior management, customers, the community, financial institutions and government regulators. Not until something unfortunate happens.

Like a loose button or pulled thread there’s been a deterioration – a few people left untrained, a couple of procedures not followed, a key piece of pollution control equipment not maintained. And so forth.

The loose thread may be spotted and repaired in time but when left unattended, things begin to unravel. In time the loose button will fall off  – there’s a major pollution incident or regulatory breach along with the high price of clean up, medical costs, fines, legal fees and loss of company reputation.  Ouch!

All elements of an Environmental Management System – like the level of training and competence and the effectiveness of operational controls – need to be rigorously checked by a program of regular internal and external audits.

The close scrutiny of a good auditor will warn the business owner(s) of weaknesses and threats so that corrective action can be taken before it is too late.

Enviroease consultants have years of experience in both audits and assessments.  Please feel free to contact me (Suzy) on 0418 862899 to discuss your needs for a gap analyses against key international benchmarks or  an evaluation of compliance for HSE.

This article was updated to reflect the revised ISO19011:2018 Guideline for Auditing Management Systems.

 

What makes effective training?

by Suzanne Orme

Deciding how much and what type of health, safety and environmental  training to conduct in your workplace can be a daunting task. Here are 5 tips to guide you through the maze.

1. Focus on high risk

Refer to the site’s Hazard/Aspect Register or Risk Register to establish the workplace tasks that may result in harm to people and the environment.  Determine the roles or job function of people commonly undertaking those tasks. For high risk activities there should be written procedures that outline the steps to take and the operating criteria that must be in place. These can form the basis of the training program.

2. Make the training measurable

Develop competency criteria for each of the high risks tasks that may cause harm. Ask “What should any person be able to do before they are allowed to work without supervision? What do they need to know? What level of language, literacy, and numeracy is required for them to function effectively?” Create a minimum set of performance criteria and a method of assessing individuals against them. For example: an observational checklist or a verbal or written test.

3. Cater for individual differences

Individuals who will be acting in the above roles may have been assessed as having skills and knowledge at a lower level than the minimum acceptable standard. Decide on the best method to address any identified weaknesses. Different approaches include one-to-one supervision or mentoring, tool box talk, an in-house group training course or a public training course by a Registered Training Organisation (RTO).

Recognise existing knowledge, skills and job-related experience when planning the approach to training and assessment. Develop training materials that are tailored to the learner’s level of LLN. In mixed groups this can be a challenge so include alternative techniques to support those with LLN difficulties.

4. Keep records

Keep records of the results of competency assessments and the actions taken when the learner was regarded as not yet competent. Retain records of training content, training provider’s qualifications and participant’s names. Even if the training is a simple “toolbox talks” you must keep a list of attendees with their signatures to confirm that they received the training.

Remember: “If there are no records, it didn’t happen”

5. Evaluate the effectiveness of the training

All elements of the training program should be evaluated to determine whether the goals of the training have been met. Are people competent? Have there been any incidents or near misses? Are people aware of how their workplace tasks may cause a significant environmental impact? Change the training content, techniques or provider to correct any weaknesses or deficiencies so that the training program improves over time.

Enviroease has 18 years experience delivering on-site customised courses direct to clients. We also deliver Nationally recognised management system training (ISO14001:2015;  AS/NZS4801:2001 and ISO19011 auditor training) on behalf of Exemplar Global accredited Registered Training Organisations.

Call me, (Suzy) on 0418 862899 to discuss how I can help with training and workshops for staff – from Senior Management teams right through all levels of the organisation. .

Article reviewed to update the last section on experience and newer versions of international standards.

Get ready for risk based licensing

By Suzanne Orme

Failure to develop and implement an Environmental Management System (EMS) at each site could become a costly exercise as the NSW EPA progresses towards its risk based licencing system.

The EPA will change the calculation of licence administration fees by introducing an Environmental Management Category – either A, B, C, D or E. The Category will act as a multiplier to the fee, resulting in either an increase, decrease (or no change). For example any sites classified as “E” will have their fee doubled, those classed as an “A” will be recognised as having the highest level of performance and receive a 5% reduction.

New approach under the Protection of the Environment Operations (General) Amendment (Licensing Fees) Regulation 2013

  • Each licence will be allocated an overall risk level of 1, 2 or 3. A higher risk level may result in more intensive monitoring and reporting obligations on the licensee.
  • Each site will be allocated an environmental management category considering the site’s enforcement history and regulatory actions, if any.  Answering “yes” to the question “Does the licensee have an EMS certified to ISO14001?” provides an automatic reduction of 40 points.  If the EMS is not certified, certain elements of a system such as records of regulator training earn points.

If you need help with waste management feel free to contact me (Suzy) on 0418 862899