Monday, October 19, 2009

14001 Environmental Management System documentation

By Mark Kaganov

Similar to ISO 9001 documentation structures, many companies certified to ISO 14001 choose a four-level documentation model that includes records. This 4-level Environmental management system is shown below:

EMS Manual - level 1

ISO 14001 Procedures - level 2

Works Instructions - level 3

Environmental Records - level 4

While auditing EMS systems like the one above, I often asked clients about the position of their Environmental policy in this structure. If you start from an Environmental Manual, how would you know what standard this manual should cover? The Environmental policy defines it and therefore it may be included into the structure:

Policy - level 1

Environmental Manual - level 2

Operating Procedures - level 3

Instructions - level 4

Environmental Records - level 5

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Document titles for your ISO 14001 EMS

Companies use various approaches to titling their Environmental Manuals, procedures, instructions, etc. For example, one of my customers titled their EMS documentation management procedure as "Documentation Management - Document Control Operating Procedure." This very descriptive title does define the document, but it does not appear to be efficient.

As a rule, regulated industries are known for calling 2nd-level documents Standard Operating Procedures or SOPs. I always wonder if these companies also have "Non-standard Operating Procedures", so these long titles differentiate them. Since a short name identifies an EMS document, I really cannot justify long names for documents. I preach Environmental Management System optimization and reduction of waste in all elements. I invite you too not to make things more difficult than they have to be to deliver the message.

Numbering your ISO 14001 documents

It is not a specific requirement of the ISO 14001 or any other standard to uniquely number a document. It is a common-sense measure and a worldwide practice in any documentation system, to give a document or a component a number and a title, and to identify its revision level. Similar to document titles that we discussed earlier, document numbering formats very often are also an opportunity for optimization.

Once I worked with an ISO 14001 certified company of less than 100 people, using fairly simple processes and having straight-forward environmental aspects. Their Environmental documentation system included a few numeration systems depending on the type of document. One of the procedures had a number 000298-001, which they simply called "one ninety eight." Drawings were numbered in a format like 123-456-33-07.

Is it not illegal to have long and difficult-to-read and remember document numbers, but it takes time to read, write and remember them. In the example above, the procedure number, without the tab, contained six digits. This meant that the Environmental system was prepared to handle almost one million document or part numbers. The company had approximately 160 documents and probably would never go beyond 200. If nothing else, just reading these numbers with three-four sequential zeros in the front may give one a headache. Surprisingly, this is not the worst case. The organization that won my "The Worst Part Number" Grand Prize assigned twelve (!) digits to their part numbers in the alphanumeric format.

I hope it is clear that only when extensive part numbers are justified, we do not have other options. If you build air planes, or Neptune space probes, you, no doubt, will need millions of parts and therefore will need long part numbers. If not, make your and your co-workers lifes easy and stay away from all those zeros. The most practical 14001 system I worked with used a three-digit format for their part numbers: 205, 206, 207 and so on. Worked just fine!

Another debatable issue with the part-numbering is part number designation. Some Environmental Management Systems associate a part number with a particular part type. For example, 20-xxx indicates a procedure, 30-xxx indicates a drawing, P-xxx indicates a policy-level document and so on. My experience with a number of ISO 14001 businesses convinced me in the benefits of a "no designation" system. Three of my clients' systems that used designation failed. Just recently, one of my EMS customers reported that they ran out of range in their part-numbering format. The EMS allowed assigning materials through a two-digit designator within the part number. When the system was designed a few years ago, needing more than 99 materials was not considered possible. Unfortunately, company's needs changed over time, and just a few years later, the Environmental Management System needed more than 99 materials causing the existing part number format to fail.

An alternative approach to ISO 14001 system part numbering is a "no designation" approach. In such a system, documents are given sequential unique numbers within a specified format, regardless of their type, material, application or other attributes. After all, isn't the part title the best designator? Through my entire professional career, I worked only with a couple of companies that did not use even document numbers. Their EMS documents were simply identified by unique titles and a two-digit revision level, like Environmental Manual 01. - 16890

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