ISO 14001:2015 - Introduction to the expected changes

The revision process for the standards is common, and ISO 14001:2015 is undergoing similar scrutiny. The draft revisions will continue as per the process that ISO follows. The working group is expected to move toward a true consensus standard following up on comments and suggestions. This is expected to be finalized by end of 2015. The standard is then expected to be good till about 2025. These fundamental changes are going to be with us for a long time. So by September of 2015, both ISO 9001 and ISO 14001 will be available in the revised format.

  The ISO 14001:2004 lays the framework for organizations to manage environmental aspects effectively and ensure protection of the environment and prevent pollution. This internationally accepted standard is proof of an organization conforming to the EMS (environmental management system) principles. The existing standard has stood the test of time, but the changes envisaged now will ensure the revised standard continues to meet emerging and future requirements and expectations of stakeholders. This is a fundamental revision to the standard similar to what is being done for ISO 9001 and what has already been implemented in ISO 27001. This is expected to be followed perhaps to publish a new standard encompassing the current OHSAS and ANSI standards with a single occupational health and safety standard under the ISO framework with the HLS (High Level Structure). The revisions will impact both the structure of the standard and the contents. 

   

   Expected Changes. The revised standard not only will have many clauses further strengthened but the order of many in the standard will change to the new structure to align with the HLS prescribed in  Annex SL. Awareness, for example, will no longer be part of competence and training; instead it will be in a separate sub-clause. The standard will provide greater emphasis on improvement. Changes to the structure will address new requirements requiring the understanding of the organization and its context as also the needs and expectations of interested parties. New clauses will address external communication and reporting, value chain planning and control and continual improvement. 

   Annex SL. The revised standard will have structural changes aligned with the HLS provided in  ISO Guide 83/ Annex SL. The look and feel of ISO 14001:2015 is expected to be functional for the management system approach aligned to the approach in ISO 9001:2015 as applicable to quality, to ISO 27001 – information security and ISO 50001 – for energy. The integrated management system approach which has been tried all these years was a challenge similar to the side car attached to a motorcycle! With the guidelines of ISO Guide 83/ Annex SL better integration of organizations management strategies.

   Leadership. The emphasis on leadership will ensure environmental management is integral to overall management strategy, policy and business development. Considering the environmental requirements as integral to the business development and continuity will require an overall consideration. The leadership will be required to further consider: 

1. Evaluation and understanding of both external and internal context of the organization in relationship to the environment. Implying that not only must organizations consider the impact of activities on the environment (as with ISO 14001:2004) but also consider the impact of the environment on the organization’s activities. 
2. Organizations will need to consider the needs and impacts of interested parties, including their supply chains and end users. 
3. Enhanced leadership commitment to include expanding the pollution prevention commitment to cover sustainable resource use, climate change mitigation and adaptation and protection of the environment biodiversity and restoration of the natural habitat. 
4. There is expected emphasis on transparency in line with the Global Reporting Initiative (GRI) and the Social Responsibility aspects from ISO 26000 requiring reporting of environmental performance. 
5. Evaluating organizational risks and opportunities in the context of external environmental conditions as adapting to climate change and so on. 

In conclusion, please stay tuned for future articles on this subject. It is important for management to know what to expect from future audits and for auditors to understand that when ISO 14001:2015 is published, it will have a new structure and text aligned to the HLS as per ISO Guide 83/ Annex SL. It will address the recommendations from ISO “Future Challenges” study for the adoption of various approaches in the field of EMS. The revision to the standard is a fundamental change.

Preparing to Implement a QMS

I was recently asked if there are preparations necessary before taking on the implementation of a Quality Management System (QMS) in an organization.

My take is involve the TM (Top Management) from the word go, collect their clear objectives. If they are not committed or clear with their policy and objectives the organization deciding to implement QMS will be an uphill task. Sure TM have asked the QM to do it, perhaps not because they believe in the system approach, but because business pressures have necessitated the certificate as a pre-requisite for gaining the business. Therefore having the objectives clear from the TM is essential. 

Once you have this TM buy in please capture the "as-is" of the system. That will start you at the correct stage of the P-D-C-A cycle which is P! This then should be followed by a gap analysis (please do not start with a gap analysis- that would be starting at the C stage of the cycle!). The gap analysis will give you the additional (missing) processes required to meet the requirements of the standard ISO 9001:2008 (or for that matter any other standard). You now will have a system ready for use by your organization. 

Then consider "what is in it for me"- as the employees question. The employees, particularly in a service industry will only buy in if they know what is in it for them. Clause 5.5.3 of ISO 9001 internal communications. Simultaneously plan some orientation to bring on board the employees so they see the advantages of a system. A bad system will let down a good man(woman) every time (Dr. Deming). 

Updating the system with a changed document control system

I was commenting on a query on LinkedIn seeking guidance on managing change when the existing document control system is to be changed. Particularly when the number of documents involved is large.  My advise from experience is: 

The first question would be to establish if the change was necessitated/ driven by a NC? If yes then the RCA should have revealed this and differentiated between Correction and CA (Corrective Action) requirements. Where immediate consequences to the NC are relevant please consider updating those documents first. This prioritization is perhaps the first step.

If this is a PAR (Preventive Action Request) prompted by a need to stay ahead and ensure continual improvement please follow a plan. The changes can be implemented in a planned manner over a period of time. Perhaps an audit cycle.

Also separate out the documents (which presumably the organization will have don). Address the policy first and follow with the update of the procedures. The number of procedures can not be very many. You should be able to address these straight away. 

The WI (Work Instructions), SOPs (Standard Operating Procedures) can then be updated in a systematic manner per the guidelines you will provide to process owners. WI update should not be a centralized responsibility. Give 3 months and provide detailed briefing guidelines on the new document control system to all process owners. They should then implement it per their priorities.

P-D-C-A helps here too! make a good plan. As you go to the D stage do some briefing and take time and make the effort to explain the requirement to the stakeholders. Then go tot he C stage, conduct an audit. Establish what is remaining and I think in 4 to 5 months the change should be done.

ISO 9001 - The Revision Process

In these last few months I have had a hectic teaching schedule where I worked on teaching ISO 9001 and ISO 14001. It was only natural that students would have questions on the changes / revisions coming up for ISO 9001 as the ISO 9001:2015 version is being considered. Many of the students wanted to know if there was a process followed to update standards or was it just ad-hoc when some one felt the need and so on. 

At Huntington, WV with the CO and students

CG students in the 5 day RABQSA certified training, in Huntington and Duluth had questions and wanted me to explain the procedure. I also received an e-mail from a student of ISO 28000 from Qatar asking a similar question. This prompted me to write a few lines on the subject. In brief here is the process for updating the standard.

    The ISO 9001 as many good thoughts has its roots in the USA. It was first published as MIL-Q-9858 in by the Department of Defense in 1959. In 1969 NATO adopted it, subsequently the UK published it as BS5750 in 1979. As ISO 9000 it was first published in 1987. The first real revision came in 1994 and this was followed by a revision in 2000. The present standard came out as ISO 9001: 2008 in 2008. The 2008 version did not have many changes. It did stress on the outsourced processes and a few changes.

  

   This new version, expected in September of 2015, however has major changes. The fundamentals remain unchanged but more standardization has been introduced to enable ease of integration of standards. More on this in a separate article.

     The main stages of a standard development are:

1. PWI: This is the Preliminary Work Item where the preliminary work is done.
2. NP or NWIP: New Work Item Proposal. The proposal is put together at this stage. 
3. WD: Working Draft. This is the preparatory stage. 
4. CD: Committee Draft. 
5. DIS: Draft International Standard. This really is the inquiry stage. 
6.  FDIS: Final Draft International Standard 
7.  IS: International Standard. This is the stage when the finally approved standard is published.

In the development of the ISO 9001:20015, the standard reached the CD stage of voting in June 2013 and the voting closed in August 2013. This is a stage where the CD is distributed to the members of the committee. It is these committee members who can at this stage distribute the CD to public. We at QMII  re-reviewed a copy at this stage. (I shall be writing on some of the expected changes shortly.)

The DIS is expected sometime in August 2014. Traditionally the DIS is available to members of the public. It is expected that the FDIS ballot will close in August 2015 and the revised ISO 9001 will be published in September 2015.

QMII conducted the RABQSA certified EMS LA (Environmental Management System Lead Auditor) training for the USCG at Yorktown. The ISO 14001:2004, together with ISO 9001 and ISO 27001 will have a revised addition in 2015. All standards in future will incorporate the HLS (High Level Structure).

ISO 9001:2015 - Expected changes from ISO 9001:2008

I did make an introductory mention to the ISO 9001:2015 standard expected to be released in September 2015. The principled changes are mentioned there. Some QMII students and alumni have asked me to write a few introductory comments on the expected structure. I have already written on the HLS (High Level Structure). In this second blog entry on 9001:2015, I want to introduce our readers and followers of my blog to the expected changes to ISO 9001:2008 when it is revised and available as ISO 9001: 2015.

In the terms and definitions itself, some changes are expected. Stakeholder remains a term but the  preferred term “interested party” has been introduced.  Audit, conformity, continual improvement, correction, corrective action, documented information, effectiveness, management system, measurement, monitoring, non-conformity, objective, organization, performance, policy, process, requirement, risk, competence, and  top management , have now been defined. 

ISO 9001:2008 has stood the test of time, and there are statistics to clearly show that there is satisfaction with the current version. However, with the change in environment and to ensure the standard will continue to deliver in the future, changes are required. The standard must meet not only customer expectations but must consistently provide goods and services that meet the statutory and regulatory requirements. In the revised standard, the term “product” is being replaced by “goods and services.” Some of the standards had different definitions and or implications for the same term. Now these terms have been standardized for all the standards. The terms “outsourced” and “purchasing” have been removed and replaced with "external provision of goods and services". Another major conceptual change is that “design and development” has been replaced by “development.”

In ISO 9001:2008, clauses under 7.3 took us from design and development planning (7.3.1) to inputs (7.3.2) to outputs (7.3.3) to review (7.3.4) to verification and validation to control of design and development changes (7.3.4 thru 7.3.7). However, the standard allowed exclusions under 7.3 since not all organizations go through each of these stages. This has now been done away with. 

The principles in clauses grouped under 4 have not changed in concept, except that clause 4.3 has left the determination of the scope of the organization to the organization. The clauses under 5 are for leadership and these in principle have not changed. Clauses grouped under 6 provide the requirements for planning. Clause 6.3 is a change in that it requires an organization to plan the changes. It replaces the concept of integrity of the system covered under clause 5.4.2 of ISO 9001:2008.

As we study what to expect under clauses 7, we see overall the concept is the same. Except in 7.1 resources, there are changes. Presently in ISO 9001: 2008, clause 6.3 & 6.4 provide the requirements for infrastructure and work environment. This has been elaborated and process environment defined together with infrastructure, monitoring and measuring and in 7.1.5 Knowledge. This new requirement on how organizations manage knowledge, understand it and deal with it is a new concept. It is still not clear if this concept will remain and be approved by the committee. Clause 7.5.3 control of documented information replaces the ISO 9001:2008 clauses 4.2.3 and 4.2.4.

Auditors as Advisers!

I received a phone call from an ex-student, wherein she as an auditor wanted to add value by using her experience and expertise in advising the management on how they should improve the system.

I asked her if she had found any NCs (Non Conformities) during the audit. She said not really but she had recommendations to make based on her experience. My response to her was to please consider that auditors and managements have distinctly different roles. Though both performing their due diligence correctly will eventually benefit the management system/ the organization. It is when auditors want to add value and virtually impose their will, ideas,make recommendations or look for a reflection of their ideas that the seed of management failure occurs. Auditors are SME (Subject Matter Experts) in auditing, the standard(s) and the process approach etc.

We must respect the organization by agreeing that the managements are the SME in their business and specialty and in meeting customer requirements and ensuring the service and goods (products) are delivered to meet requirements. If they do not meet the requirements, the greatest service we do as auditors is to provide a correctly written NC.  It is for the management to follow up on the NC and carry out RCA (Root Cause Analysis).

Is she not obliged to assist in RCA and problem solving as an auditor? My response is that RCA and problem solving starts when auditors leave. Of course there may be occasions when as internal auditors you perhaps wear two hats; a challenging situation. Yet with a little maturity it can be ensured that the two roles are not mixed. Verification which follows the implementation of the RCA results, does indeed, need a little "research", but might I suggest, not of what you as an auditor expect, but of what is acceptable to the organization.

I further advised my readers to consider that by giving advice are you taking on the management's role? From my experience, whenever auditors do that, they slowly kill the management. Often the first step in that death of an organization is that the management just does what the auditors recommend/advice, forgetting their role at the Act stage of the P-D-C-A cycle in terms of Management Review (MR) clause 5.6 of ISO 9001. Please always remember the role of the auditors in the 'murder' of Enron. Yes with your consultant's hat, it is acceptable. I agree. After all the managements use consultants, not auditors, for advice.

Introduction to HLS - High Level Structure

At QMII since 1986 we have been introducing and encouraging the integrated approach to management. As President and CEO of QMII I have emphasized this specially to the maritime industry, where for example a passenger line is meeting various demands related to passengers, food related, health and hygiene related and to an extent considering social responsibility aspects as a requirement to encourage passengers. Having discrete systems makes the implementation a challenge.

It is therefore very heartening that as the ISO 9001, ISO 14001 and ISO 27001 are being revised the standards will all incorporate a common structure which will make implementation of an integrated system a reality. All future standards starting with ISO 9001:2015 have incorporated this change. The purpose of the HLS – Higher Level Structure is to ensure all future standards (as they get revised) will have identical text covering the common components. Actually ISO 9001:2015 will be the second standard to adopt this. The standard on Business Continuity Management ISO 22301:2012 already incorporates this HLS. ISO 14001: 2015 too will incorporate the HLS.

So what is this HLS? All standards as of date already have Introduction clauses which under 1 cover scope, 2 to cover normative references and 3 to cover terms and definition. These will be the same in all standards and so remain unchanged.

The changes that the HLS will bring in are that all standards will now look the same and the other clauses would be grouped as follows:

4- Context of the organization

5- Leadership

6- Planning

7-Support

8-Operation

9- Performance evaluation

10- Improvement

This will then be followed by the Appendix and Bibliography.

For readers who are already familiar with the existing ISO 9001: 2008, please note these changes to the structure.

More detailed inputs/ comments on the structure follow in future articles. Please stay connected to the blog.

A System Failure: Explosion and sinking of Indian Navy Submarine Sindhurakshak

Explosion and sinking of INS Sindhurakshak, a conventional Indian Submarine in Mumbai harbor shocks the world. Is it another case of system failure?

The recent explosion on an Indian Navy submarine in Mumbai (Bombay) harbor and its subsequent sinking with the tragic loss of 18 service men of the elite submarine force of India has been in the news. Before migrating to the USA I saw served in the Indian Navy's submarine arm including on India's first nuclear submarine. The views in subsequent paragraphs are based on my experience and now my expertise on the system approach.

The submariners in India have for long not been recognized or given the respect due to them. There are several reasons for this, what goes up can be seen and is glamorous as the Indian Air Force (IAF).  The Indian Army has visibility; it has been the guardian of the country and perhaps the only insurance against the corrupt and unscrupulous politicians in keeping India secure. So there is respect for the army, and to an extent a commitment to supporting it.  In the case of the Indian Navy the understanding of its need and the national commitment to it has been scanty and inconsistent.

India is a peninsula jutting into the ocean with an ocean named after it. No other country really has an ocean named after it. India has this privilege. Has always had it, but never realized it and consequently appreciated the value of protecting the sea front. The strategies of keeping sea lanes open have not been appreciated by the intelligentsia, then what to talk of the large population living in poverty and preoccupied in making two ends meet.

Submarining and its risks are not really appreciated by the mass of India. There are virtually no family members of any elite or politicians in the armed forces then what to talk of any of them serving in the submarines. The elitist respect comes from the public understanding and appreciating the sacrifices of those at sea and more so under water. What goes up may come down, but what goes down may never come down!

In Russia, where I trained with the command team for the first nuclear submarine, in every house the third toast is drunk to all those at sea and then to submariners. Armed forces from Chandragupta Maurya's time were respected and integral to the advice provided by Chanakya to the rulers.  The degradation of the political set up has over the period put those in power who do not really value the services. Some of them laugh at them forgetting that they are secure to play their dirty games because the services keep the nation secure.

Some of India's politicians and rich and affluent visiting the US should spend less time in malls and perhaps a few hours in the Arlington Cemetery! The next time they are in US they should spend time studying the respect any great nation should have for those who protect the nation. I say all this not out of context to this tragic incidence, but because this lack of support from the nation has a great bearing on such accidents. The scenario results in a demotivated service, always thinking of those all around enjoying the bliss of corruption. Sometimes even regretting the choice of their careers, whilst these committed submariners go around Mumbai on their bicycles cursing the misery of their difficult life with no national support to them or their families. This results in mediocrity in services. No one or very few really joins the service as a first choice.

The weaponry and platforms are sophisticated and require a committed manpower enjoying what they do.

Against that backdrop consider the responsibilities the services have.  Every time India has lost her freedom it has been when she was attacked from the sea. Those who came from the land routes invariably stayed and got absorbed into the system. So there is this dichotomy between expectations and responsibilities on one side, and the demoralized work force trying to run around Mumbai competing with the rich and affluent.

These tragic accidents need to be analyzed against this back ground.

Torpedoes do not detonate and explode if the processes and procedures are correctly followed. If the officers and men work as a team. Train and drill with enthusiasm. These sad incidents are indicative of a system failure and do not auger well for the future unless the system is reviewed. The review of course must not start at the check stage of the P-D-C-A cycle (Plan- Do- Check- Act). It must take the country to the Plan stage and then back to what and how they want to implement a strong armed forces and then go on to the Check and Act stages.

Indian system has run since independence guaranteed as insurance by the efficiency of the armed forces. That the strategic thinking, the national policy should take this into account and be discussed by the intelligentsia, debated by the nation not only in its parliament but in public forums. For this clear policy then will create the organization ready to create the system which will ensure efficiency and meet national objectives.

Regrettably in India none of this is analyzed publicly. If anything everyone has a stake in hiding the truth. The bureaucrats and the services and the politicians will blame each other for not funding and talk about lack of spares et all or blame some individuals. Perhaps the Commanding Officer of the submarine or the Commodore commanding these submarines and so on will be blamed. And if at all they are to blame, then the system too must take the blame and admit they have placed incorrect personnel in positions of national decisions making. In case the system for the selection is incorrect then the individual cannot be at fault. The root cause has to be searched elsewhere. In either case the system is to blame. As Dr. Deming stated “a badsystem will defeat a good person every time”.

 The nation itself by and large does not involve itself in the discussion. If it did it would see that the sacrifice of these 18 soldiers who were doing their duty to the nation will not go waste. In my opinion this is not an individual failure. It is a system failure. The absolute top management should take the responsibility. The defense minister and then down the line should analyze the system failure which has its fountainhead at the Top Management.  The Defense Minister is the top management for the defense forces or not? Has the system failed or not?

It is not a system failure at the submarine level (INS Sindhurakshak – Protector of the Seas), or at the entire submarine arm level or at the navy level, but at a national level. The nation is failing the services and so the resourcing in every form (manpower or hardware or software) is lacking and being worsened by a deteriorating morale of the troops. Keeping the services in top form is a national commitment. When the nation is proud of its services and supports them and respects them and treats them distinctly with the privileges they deserve it is a lot easier to implement the rigors of discipline by setting example and leading the system.

I fear many more accidents and mishaps in every service, including perhaps the reluctance to fight can be the result if this system failure if analysis is not carried out on priority basis by India. The basics of the system approach in ISO 9001:2008 would help the country put the house in order.

No one likes to die. The military leadership leads the men by training in peace time to reach a level where the men have the morale to fight including to happily sacrifice for a cause. This demand for high morale in the troops is a national requirement and demands support at the national level.

I can sum it up with my past experience in the Indian Navy, including accidents seen by me in the Indian Navy’s submarine arm, including a nuclear accident which was never really publicly analyzed and would say that India may rise above from this tragedy a better force if the fundamentals of objectivity in using the system are utilized. India has operated submarines safely in the past. The Indian Submarine arms safety record is exemplary. It is because procedures were always followed howsoever uncomfortable and inconvenient. The subs are safe till complacency sets in and makes the crew forget that they can be dangerous!

What happened in this case may never really be made public. Though I think the SOPs (Standard Operating Procedures) may have been neglected. You cannot be arming the fish (torpedoes) or any other weaponry on a/ with a duty watch. The submarine should be at action stations. From the death toll it is apparent they were not at action stations. Easy then to blame the CO (Commanding Officer) for this blunder! Blame the individual and close the case. Hope not. Time to look at the system failure at the highest levels.

Training: A Luxury or Strategic Necessity?

Well-developed management systems are developed and implemented to drive efficiency in organizations.  These systems when implemented ensure that  the organization does not become vulnerable or lose its integrity when key personnel change as also during any mergers and splits in organizations. Just as technology is constantly upgraded, so must human potential. In any organization, large or small, training which needs the least investment can play a very important role given the critical contribution by human resources in ensuring efficiency. The necessity of training in building human potential and productivity to ensure optimization of human resources can hardly be emphasized.  

Top Management often go in for implementation of management systems without answering the employee’s question of “what is in it for me?” Training and exposing 10 to 15% of the manpower to management system related standards for efficiency (ISO 9001), risk management (ISO 33000), the environment management (ISO 14001) and security of the global supply chain (ISO 28000) quite prepares them for the system implementation. Some  organizations might choose to implement an integrated management system encompassing all or a combination of two or more of the above standards.

Organizations view training as a luxury and often not as a strategic necessity. A well trained manpower is a great asset in getting the “job done” . When budgets are cut training is often given a low priority. In difficult financial situations when all else costs the organizations so much more, a little investment in well trained manpower results in rich dividends and ensures human capital continues operating at their peak efficiency as a motivated work force even through bleak periods thus ensuring a continually efficient system. As a system is developed and put into place a trained workforce helps to better implement the system and results in a ‘buy in’ of the entire team. A team that appreciates the important role that a well implemented system plays in increasing the efficiency of a system while reducing non-conformities (NC).

As NCs are embraced to drive continual improvement the number of problems affecting the system reduce and the work force has its answer to "what is in it for me". This gives the organization strength in depth and provides more time to innovate and thus continually strive for new heights of excellence.

The benefits of training are intangible but below are listed a few: 

• Better output

• Higher Retention 

• Team Spirit 

• Improved corporate Image 

• Higher morale 

• Improved Profitability 

• Fewer Accidents

A small investment in training will ensure an oriented manpower, familiarized and ready to implement and meet the management’s system objectives and align them with the organizations aim of doing much more with much less.