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For those of you who have ever had the opportunity to witness the high jump event at a track and field meet, you have seen the challenge faced by the athlete as they raise the bar to the personal limit of the contestant.   As a frequent spectator to such events, the experience of seeing the athlete reach their personal limit has certainly been rewarding.  In a similar line of thought we have seen organizations that have achieved certification of their Environmental Management System (EMS) to the ISO 14001 Standard face the continuously rising bar of surveillance audits.   This too has been a positive experience for us as consultants when a client is able to rise to the occasion and meet this challenge.

A registrar (who will remain anonymous) once told us “it is much easier to be initially certified to the standard than it is to maintain the system”.  This simple piece of advice has proven to be the truth as far as the experiences we have encountered with different clients and registrars.  For most organizations who commit to pursuing ISO Certification, there is an all out effort and unity of purpose to achieve this goal.  Management commitment is in evidence, and the engineering mentality well engrained in many companies of driving a project to successful completion takes place.   Once the banners are hung and the celebration of being certified is over, the real strength and commitment to the EMS comes to pass.  That same mentality that drove the project typically moves on to the next project or issue.

Unfortunately, this is where the system for many companies begins to unravel.  Too many people have the “been there, done that” attitude towards their EMS, and forget the basic premise that the system needs to evolve and improve with time in order to face changing realities.  One of the most common issues impacting business during periods of recession is the need to scale back expenditures for projects, even those that are economically and technically viable due to reduced cash flow into the company.  This basic fact of life of not being able to spend capital during slow periods tends to throw a damper on the ability for organizations to accomplish the objectives and targets of their EMS.  They begin projects with the best intentions, but half way through the economy falters, personnel are laid off, orders are down, and all the other ramifications that occur in this situation impact the EMS as well.  Projects that are started and halted due to changing economic realities should not be left hanging.  Instead, the work that has been performed should be well documented, and the fact that the project is on hold due to financial reasons should be clearly stated.  In fact the effort to conduct the project was there, the research or testing may have been performed but the lack of funding has driven it to the back burner.   A registrar can then review the project work, and witness that the effort was there, and realize the reason the objective was brought to conclusion.  A common weakness we encounter when helping companies maintain their EMS is a lack of routine documentation of a project status, especially when the cash flow has dried up.  This is an area that registrars routinely look for, they need to see that the effort has been put forth even though objects and target are often not met for either technical reasons or the lack of funding.

It is in these periods that a system needs to prove that it is both dynamic and flexible to adapt to the changing economic reality.   With the capital money temporarily unavailable, new and innovative ideas that will reduce environmental impacts need to be considered.   There is nothing in the ISO 14001 Standard that says that continual improvement in the system should be the result of large expenditures.  In fact, improved environmental performance can be composed of a series of seemingly small changes, adding up to a larger whole.

The idea is for companies to recognize this in slow times, and put in place those things that will add to a cumulative improvement in the EMS.   One element that most organizations should be able to afford is to improve the quality and delivery of environmental training.  Every program out there, in reality, presents the opportunity to be improved upon.  Improvements in environmental training programs really accomplish two things; they will increase awareness of the subject matter, which should have a beneficial impact and will provide evidence of direct improvement in the system, either in the course material, delivery, or in trainee retention.   These things are clearly demonstrable to an auditor who is raising the bar during the first or second surveillance audit of the system.  Most surveillance audits involve the registrar interviewing random employees about their role in the system, or what they would do in an emergency.  A well-trained workforce will shine in such a situation without the expenditure of capital.  In theory, when production activities have slowed more time should be available to conduct training and involve staff in improvement projects.

Other areas that can be linked together during tough economic times are quality and environmental issues.  Simply, any improvements in production processes that cause less rejected product will reduce waste production, energy and raw material usage.  Clearly, this activity will benefit both the environment and the bottom line, and may be necessary to insure the continued viability of a financially troubled company.   It is important therefore, that the EMS become interwoven with the overall business goals to remain profitable and eventually increase productivity.  This is part of the evolutionary process of the system mentioned earlier.

Just as raising the bar at a track meet pushes an athlete to their personal limits, so does the expectation of registrars performing system audits that the EMS needs to demonstrate improved performance.   This driving force will force companies with true management commitment to become innovative in their approaches, and like an athlete who must train to improve; the effort must be genuine if they hope to rise to the occasion.

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