Are your management system documents out of control?

by Suzanne Orme

At last things are getting easier!

Long gone are the “typing pool” days of the 70’s and 80’s. The 90’s heralded the age of the “e-document”, predominantly Microsoft Word and Excel. There was a shift away from the massive archives of printed materials that waste paper and create a fire hazard. But this leap forward came with a downside.

We all know that the enhanced ability to create, modify and transmit documents quickly has encouraged excessive documentation coupled with the ongoing challenge of controlling and keeping them up to date. What typically happens?

  • People access an earlier, superseded version
  • Records are inadvertently deleted or lost
  • There are too many forms to fill in and registers to update
  • People have difficultly finding a particular document
  • People print documents or copy the “controlled” version onto their desktop

Any of this sound familiar?

Thankfully the International Organisation for Standardisation (ISO), has come to the fore by reducing the emphasis on documentation for HSEQ Management. For Environmental Management Systems, ISO14001:2015, there are 32 clauses containing requirements. Only 18 of these explicitly state that the organisation must “maintain documented information”. For ISO45001:2018 Occupational Health and Safety Management Systems, there are 17 such clauses.

The extent of documented information will vary due to these factors:

  • Size or the organisation and its activities, products and services
  • Need to demonstrate fulfilment of compliance obligations
  • Complexity of processes and their interactions
  • Competence of persons doing work under the organisation’s control

Some alternatives to documents include: visual aids; engineering controls; training; supervision; demonstration and experience. Information may be incorporated into alternative media such as videos; photos; electronic signs and mobile phone alerts, to name just a few.

Now is a great time to assess whether each document in the management system is needed and if there is anything missing. I’ve created a set of questions that can assist you in this endeavour.

  • Does the document duplicate another document?
  • Is there a legal or contractual requirement to create a record or report?
  • Does the ISO standard state a requirement to maintain or retain documented information?
  • Would the lack of a document create an operational or strategic risk?
  • Could the document be integrated with another document?
  • Is the document needed for training or communication purposes?

Since the release of ISO45000:2018, the desire to integrate Workplace Health and Safety with Quality and Environmental Management can be much more easily accomplished.

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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.

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


Opportunity: a new way to think about risk

by Suzanne Orme

People usually think of risk as a bad thing –  the exposure to danger, harm or the potential for losing something of value.  Whilst it is essential that business leaders identify and reduce the likelihood of these consequences, it is equally important to consider how the same sources of risk can represent opportunities to strengthen the business.

I’ve recently discovered that the added-value potential of opportunities can be determined in a very similar way to assessing the risk of harm. Its not at all difficult and can add rigour to the planning process, highlighting the actions for the business to prioritise.

The new ISO management system standards define risk as the “effect of uncertainty”.  An effect is “a deviation from the expected – positive and/or negative”. Uncertainty is the “state, even partial, of deficiency of information related to, understanding or knowledge of, an event, its consequences and likelihood”.  This tells us that risk is not necessarily a “bad” – its just something we all need to manage.

Non-fulfilment of interested parties’ expectations poses strategic risks beyond mere reputational damage – loss of a key customer, huge financial penalties, court action or revocation of the site license to operate.

Executives who are proactive and improvement-focused determine key stakeholders and put processes in place to actively engage with them.  Common expectations that relate to the environment are the prevention of pollution, energy and resource efficiency, biodiversity conservation and the minimisation of nuisance impacts – noise, vibration, odour and dust.

For worker health and safety, its the elimination of hazards and the systematic reduction of work-place accidents, injury and ill-health. Many of these broad expectations are shared by more than one stakeholder group – so its not too difficult to conduct a simple, top level review and keep it up-to-date.

But let’s be mindful that businesses don’t exist in a vacuum. Proper identification of the sources of risk and opportunity involves more than knowing customers. It involves scanning the entire internal and external environment to determine the relevant issues at any given time.

Consider the political/regulatory situation; economic/financial issues; social/community expectations; technological advancements and the natural environment – mother nature herself. These are sources of risk and opportunity that are constantly changing.

Most HSEQ systems lack a clear and transparent process for stakeholder needs identification, risk and opportunities assessment and the incorporation of risk in decision making. But doing this well is not only good business practice, its a requirement of the new international standards.

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This article was updated in May 2018 to reflect the release of ISO45001:2018. 

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.

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

How do you take a life cycle perspective?

by Suzanne Orme

While presenting a series of one day courses on behalf of SAI Global entitled “Preparing for the transition to ISO14001:2015″ I became aware that one of the concepts in the Standard is new to many people. Its the taking of a “life cycle perspective”.

So, what does this mean?

A life cycle is defined in the Standard as the “consecutive and interlinked stages of a product system, from raw material acquisition or generation from natural resources to end-of-life treatment”.

Life cycle assessment has been around since the 1990’s and is often called the “cradle-to-grave” approach for assessing industrial systems. This begins with the gathering of raw materials from the earth to create the product and ends at the point when all materials are returned to the earth.

LCA enables the estimation of the cumulative environmental impacts resulting from all stages in the product life cycle, often including impacts not considered in more traditional analyses (e.g., raw material extraction, material transportation, ultimate product disposal, etc.).

By including the impacts throughout the product life cycle, LCA provides a comprehensive view of the environmental aspects of the product or process and a more accurate picture of the true environmental trade-offs in product and process selection.

It should be noted that a full LCA on each product is not a requirement of ISO14001:2015. The introduction of the term “life cycle perspective” will simply translate into a stronger expectation for companies to consider how their decisions impact further upstream or downstream of its operations.

They will need to demonstrate how they used their influence on suppliers, contractors, customers and consumers to improve sustainability across the supply chain.

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This article was updated to remove the word “draft” after the final version of ISO14001 was published.

Envisioning a clean water future

By Suzanne Orme

There have been large improvements in the quality of the world’s water resources over the last 25 years. Since 1990, 2.1 billion people have gained access to improved sanitation. The UN estimate that 91% of the global population uses an improved drinking water source, compared to 76% in 1990.1 That’s the good news. Now for the challenges.

Agricultural and coastal development and inadequate sanitation near river catchments still cause significant amounts of sediments, nitrogen, phosphorus and pesticides to be washed into the world’s seas.

Nitrate concentrations continue to climb and recently the United Nations Environment Program (UNEP) reported 169 coastal dead zones across the globe with only 13 recovering and 415 coastal areas suffering a reduction in dissolved oxygen.2  The association with coral bleaching and polluted run off is well known.3

In 2012, 288 million tons of plastic were manufactured globally and 8 million tonnes of this was dumped into the world’s oceans.5 Almost 90% of the marine debris found on Sydney’s beaches is plastic, mostly bottles, caps and straws.6

Ocean plastic has been found in the deep sea and buried in Arctic ice. It has been ingested with dire consequences by some 700 species of marine wildlife. The plastic doesn’t break down completely and some of it ends up in the seafood we eat.

A clear role for business

As 80% of marine pollution comes directly from sources on land 2, improved practices by factories, farms, transport operations, mines, construction sites, oil and gas facilities and power generation plants can make a significant difference to the state of the world’s oceans, rivers and ground water quality. To contribute to cleaner oceans, businesses can adopt the following steps.

1 Develop an understanding of water quality issues relevant to each facility

Identify all types of effluent and pollution leaving the company’s operations as surface or groundwater in a typical year. Record the total number and volume of significants spills, their location, volume and the specific contaminant. Find out the total water discharged by quality and destination and whether these were planned or unplanned; the water treated or untreated and the amount that was used by another organisation, meaning it was diverted from release into the environment.

2 Determine the level of associated threats, risks and impacts

Consider potential risks associated with the effluent and pollutant discharges you’ve identified. These may include fines, legal costs, loss of licence to operate, clean up costs, negative media, harm to flora and fauna, human health impacts and economic impacts on farms and fisheries.

3 Seek out ways to achieve zero water pollution leaving the facility

Go through a process of identifying and assessing improvement ideas. Aim to eliminate the discharge of oils/fuel, chemicals, sediment and solid waste into stormwater drains or areas where rivers and groundwater could be adversely affected. 100% of runoff should meet ANZECC water quality guidelines for the concentration of nutrients phosphorus and nitrogen, acidity, dissolved oxygen, salinity and turbidity. Investigate whether there are ways to treat waste water for re-use in another process. If there is an EPA licence or trade waste agreement (TWA) set an objective that all water quality samples will meet the required parameters.

4 Use your company’s influence to have a positive impact elsewhere

There may be opportunities to improve water quality by undertaking remedial works outside the company’s operations. Some performance indicators around this might be:

  • The number of or Km2 of local creeks or rivers rehabilitated
  • The no. of, kilolitres or percentage of spills cleaned up and the specific contamination eliminated
  • Kilolitres and percentage of total sewage or effluent treated for re-use by another organisation
  • The Kg or number of pieces of litter cleaned up from local streams, river or beaches, for example on “Clean Up Australia Day”

Your company may be able to improve water quality indirectly through the purchase of resources, provision of products and services, R & D processes and supply chain collaboration. For example, researchers at Flinders University have developed a new polymer that cleans up mercury from waterways, soil and groundwater using waste sulphur from the petroleum industry and waste limonene from the citrus industry. 4

Health and Beauty multinationals, Unilever and Proctor & Gamble are phasing out the use of microplastic ingredients in their facial scrubs and other cosmetic and toiletry products. 7

We have a range of services to help you improve the way that water discharges and spills are managed across your company’s operations.

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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.

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What the revised ISO14001 means for you

By Suzanne Orme

An updated version of ISO14001 was published in September 2015.

The new version is intended to maintain and improve the basic principles and existing requirements of ISO14001:2004.  The new elements and requirements, summarised below, bolt on fairly easily to any ISO14001 based system.

However the new clause numbers and structure pose more of a challenge.  It is based on a new high level structure for Management System Standards, called Annex XL, different from the “plan-do-check-act” principle that management system practitioners are familiar with.

Changes include:

  • Specific responsibilities for people in leadership roles to promote environmental management within the organisation.
  • A new requirement to understand environmentally-related organisational risks and opportunities and to integrate those that are critical into operational planning.
  • An expanded expectation to commit to proactive initiatives to protect the environment which can include sustainable resource use, climate change mitigation and adaptation and protecting biodiversity and ecosystems.
  • A shift in emphasis from continual improvement of the management system to improvement of environmental performance
  • An extension of control and influence beyond procured goods and services to  product use and end-of-life treatment or disposal.
  • The development of a communication strategy with equal emphasis on external and internal communication and quality of information.
  • Use of the words “documented information” instead of “documents and records” recognising the use of computerised systems.

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This article was updated after release of the standard.

Are we exposed to too much lead?

by Suzanne Orme

Lead is a highly potent nerve toxin that has been known for decades to have devastating effects on human health and wildlife as well as strong links with violent crime.

While the phase out of lead in petrol has been an outstanding success globally, there is still a long way to go.  Technical innovation, stricter controls of industrial emissions, a ban on certain imports and exports together with the enforcement of more stringent air quality standards are required to protect people in all towns and cities.

Whether you and your family are exposed to too much lead depends largely on what job you do and where you happen to live.

Like other heavy metals, lead is hazardous to animals and dangerous to humans as it accumulates in soil, livestock, fish, mammal, human tissue and blood. At all levels of exposure it can cause adverse and often irreversible health impacts to the nervous, immune, reproductive and cardiovascular systems.

Even very low levels of lead in infants can have serious and permanent effects on IQ, a link that is well documented.  Lead impairs the development of parts of the brain that regulate behaviour and mood – the anterior cortex and prefrontal cortex.

As early as 1943 studies showed that infants that had chewed lead off the side of their cots were highly predisposed to aggression and violence, years after the exposure.  Some interesting studies indicate that 20 years after lead had been banned in many cities there was a noticable reduction in violent crime.

A 2011 article in Journal of Environmental Health by authors Tsai and Hatfield estimated the economic benefits of the phase out of leaded petrol and consequent reduced health risks to be worth US$2.5trillion/year, or roughly 4% of global GDP.

The bad news is that lead is ubiquitous in our society. It is still commonly used in pigments, dyes, some paints, coatings, batteries, ammunition, metal products and devices to shield X-rays. Lead compounds are used in the manufacture of matches, ammunition, fireworks, explosives, pottery glazes, ceramics, brake shoes, flame retardants, electronic parts, plastics, rubbers and as catalysts for industrial production and epoxy curing agents.

People who work in industries that manufacture or use these components may be at greater risk of exposure as are those living near large point sources of lead emissions. At Port Pirie, 250km north of Adelaide 25% of children aged under 5 were found to have blood levels in excess of 10 micrograms per decilitre of blood.

Despite all the research highlighting the dangers, Australian exposure levels for children aged 3 – 14 years remains at the level set in 1993 by the National Health and Medical Research Council (NHMRC). This is 10 micrograms per decilitre of blood, well above the USA of less than 5 micrograms and Germany, less than 3.5 micrograms.

I support the recommendation made in the Medical Journal of Australia for a standard of one microgram per decilitre of blood together with improvements in how lead sources are identified and controlled.

The problem of toxic air emissions is more acute in developing countries. For example, fewer than 1 percent of the 500 Chinese cities studied by the Asian Development Bank and Tsinghua University met the air quality standards recommended by the World Health Organisation (WHO). Poor air quality is caused by coal fired power plants, other industrial sources and vehicles exhaust.

To ensure that the world develops on a sustainable path, research, innovation and technology transfer are now urgently required to phase out toxic substances. Substitutes for lead must be found if we are to protect the air we breath, our wildlife and the world’s children from the devastating effects of lead poisoning.



Two ways to avoid digital misinformation

by Suzanne Orme

With today’s appetite for rapid and instant communication, the media have developed a tendency to rush information out quickly without subjecting it to proper editorial oversight and scrutiny.

In NSW last month an anti-coal campaigner using only a laptop and mobile phone was able to issue a bogus media release stating that the ANZ bank had reversed a AU$1.2bn loan to Whitehaven Coal.  The result was that $314 million was temporarily wiped off the value of the company.

While the activist’s ability to draw attention to the climate change issue has been applauded as commendable in some quarters, I suggest that fraudulent behaviour only serves to discredit the reputation and cause that the perpetrator is trying to promote. In the words of Plato “whoever is detected in a shameful fraud is ever after not believed even if they speak the truth”.

There have been instances where deliberate misuse of the internet has had devastating effects. According to a CBS News Report “Egypt Fights Cartoons with Cartoons”, riots across the Middle East were sparked by a YouTube video entitled the “Innocence of Muslims” and over 50 people were killed in violence related to the video in September 2012.  See

In its recently released  “Global Risk 2012 Report”, The World Economic Forum identified massive digital misinformation as a real  risk for the world economy over the next decade. Respondents to the questions on which the report  is based  linked it with other risks such as data fraud/theft, cyber attacks, terrorism, systemic financial failure and the breakdown of governance and diplomatic conflict resolution. The report discussed how enhanced hyperconnectivity together with open and easily accessible information could cause havoc in the real world.

But the WEF report rightly points out that controlling the spread of digital information through national laws or sophisticated technologies raises sensitive questions on the limits to civil liberties – a human value that is not regarded equally across different countries.

Censorship limits freedom of speech and what authority could ever be trusted to intervene to eradicate what they perceive to be false information? There may be an even greater danger of “misguided attempts to control such access”.

So what can you do?

Apart from healthy scepticism, I suggest that there are two things that individuals and companies can do to prevent falling victim to digital misinformation.

1. Check that the source of the information is legitimate and that the press release, video or email originated from the company claiming to make it. Go to the company’s website to see if the information is duplicated there. If you can’t find what you are looking for, ring up and ask.

2. Check that the information has been verified by a recognised body.  Company issued reports usually include a statement as to whether the information contained within in it has been independently verified. Again, if you are not sure, ring up and ask.

The job of verifiers is to identity what is called a “material discrepancy”.  This is a mistake, omission or set of errors that distort the meaning of the information to the extent that those relying on it may make a wrong decision with negative consequences, usually financial loss.

So if the auditor/verifier is competent in the task, it follows that the report or claim should be reasonably free of distortion and can be confidently relied upon when making decisions. Let’s hope.