ISO 9001 Certification versus ISO 9001 Conformity

All organizations can benefit from making sure their organizational management system conforms to ISO 9001.

Certification provides marketing benefits to organizations whose customers value the independent certificate and the registrar that issues it.  Certain new customers may provide a new supplier with a certified management system with an opportunity to prove they can fulfill their requirements.  Certification reduces the risk for a new customer trying out new suppliers.

Existing customers often are not impressed with certification because they already know how well your organization, as a system, performs.

For organizations that work in markets with customers who have no interest in certification it is better to quietly make sure your management system conforms to the standard.  This provides confidence that requirements will be fulfilled and are being fulfilled.  It also enables continual improvement of products, processes and the management system to prosper and grow.

Certification has initial cost and then recurring cost when the registrar comes in at least every 6 months. The benefit of conformance is the system is always ready and when marketing demands require you can go ahead with certification.

To learn more about the benefits you can email me at info@qmii.com

ISO 9001:2015 ... What can we expect?

In this fast moving global environment the flexibility permitted by the international standards, whereby interpretation of the standard, correctly makes it applicable to "all organizations, regardless of the type, size and product provided" - Clause 1.2 of ISO 9001. Never the less to keep the standards aligned it is essential that they are updated on a regular basis. TC-176 works on ISO 9001 and considers and evaluates the inputs from users and SMEs (Subject Matter Experts) in the intervening period. The ISO standards are generally revised every 5 years. ISO 9001:2008 is now due for a revision.

In 2015 we will have the revised standard which should come out as ISO 9001:2015. QMII keeps track of the changes and ensures our alumni and students are always updated.  The process involves submitting  our comments via bodies affiliated with BSI in the UK and ANSI in the USA.  The CD is available and there is a lot to sort out before it becomes the DIS. However I do see that lot of training providers have already put out the draft standard for review! In fact some are offering courses to learn it!!

We should really be waiting for the DIS. Once that happens we too will update our course material to prepare our students for the changes in 2015. There are no worries there for the current users of the Standard. As always every organization is given a period of two years to comply with the new standard. Thus ISO 9001:2008 should tentatively go out of date sometime in 2017.

You can review the scrubbed version here. Please remember it is for "Review Only" as an advance copy. I would encourage you, our readers, to challenge yourself by reviewing the scrubbed version and recognizing the changes compared to the ISO 9001:2008. You may comment on the differences here, on the scrubbed version link or by sending me an email at iarora@qmii.com.

Please watch this blog. I shall soon put my comments to keep you updated and advised.

The Recipe for a Successful Merger

Mergers and acquisitions challenge the system. The system goes through a phase where integrity of the system can be affected if meticulous planning is not carried out. While having experienced and capable personnel to lead this evolution is essential and desirable, we must not forget that "A bad system will let down a good person every time". Therefore the emphasis on looking carefully at the existing systems and then designing the new system based on the "AS-IS" of the system led by a clear policy from the Top Management is essential. Every merger brings  a sense of excitement within the organization. There is prospect of growth, not only for the organization but also for all the personnel employed. It is not surprising that not all mergers are successful. There have been many a case of failed mergers, some having failed within a few months. The value and benefits of a well implemented process based management system cannot be stressed enough. This applies equally across all industries.

A well-developed process based management system ensures that all processes are established and functioning well and will not be adversely affected as the merged organizations place the new personnel in their roles of responsibility. The authorities and responsibilities need to be well defined. The policy should be seen in the light of the revised organization and should put in place clear measurable objectives and goals. The system should help identify non-conformities (NC). Most companies fear NCs not realizing their importance. Although initially there might seem to be an increase in reported NCs in a well integrated and implemented system these NC’s will eventually lead to a culture of Preventive Action opposed to Correction & Corrective Action post an incident/accident.

Is it merely enough to have a system in place though? At QMII we work with our clients hands on to recognize the  "As-IS" of the systems and meticulously work to integrate them into a harmonized system so that the integrity of the system is not lost as the merger progresses. The lack of ‘buy-in’ by Top Management (TM) to the new system creation or the TM saving pennies at the P stage of the P-D-C-A (Plan-Do-Check-Act) cycle can have adverse consequences and are the precursor for a dysfunctional system in the future resulting in losses. The organization pays for the poor planning of the system.. It is important to have the Top Management lead the implementation of the new system and this will then filter down the ranks effectively.

For a maritime organization  a well-integrated Safety Management system complying with the ISM code ensures that all aspects of logistics services, cruise services, vessel management, ship maintenance, personnel training and commercial trading operations performed throughout the company fleet work effectively to ensure the success of the company.

This might sometimes involve developing a completely new system. However at QMII we strongly urge our clients and alumni to ‘Appreciate their Management System’. That respect for the existing system comes from avoiding templates (one fits all!) and instead going to the “As-Is” of the existing systems before integrating them. Then the gaps can be identified and effectively filled. (See our methodology). This makes it easier for all employees to ‘buy-in’ to the integrated system and leads to a successful merger!

Why should SME (Small and Medium Enterprises) implement ISO 14001?

Our senior consultant Tom Venafro has been working on EMS (Environmental Management Systems ) all his life. I was having a discussion with him and asked him, “Why should SME (Small and Medium Enterprises) implement ISO 14001?” In fact more, why are they reluctant to meet this responsibility. Are these companies even aware that just being efficient (using a system based on ISO 9001:2008) may ensure efficiency, however unless the byproducts and pollutants which are the result of a process are controlled the organizations will eventually see a declining “cash in the bank”. Going further, and learning from 9/11 we know that an efficient system should not only take care of the environment to be profitable and viable but must be secure. The implementation of  a system to protect the global supply chain based on ISO 28000 needs to be considered as an asset. Social responsibility is integral to good business today. On ISO 14001 Tom had the following views:

Small and medium business should be considering ISO 14001 EMS for their sustainability in more ways than one. Of course having a certified EMS will provide both a green "sustainable" future as well as a green "monetary" bottom line.

Aside from and implemented EMS being the right thing to do for the environment, it also reaps financial benefits.  Recycling programs means less waste to landfill, less regular waste pick-ups more money saved. The EMS will provide the framework for a company to be a good steward of the environment and help reduce its impact on the environment. This equates to more control over pollution sources and less fines from regulators and huge "cradle to grave" liability.

These items are just the tip of the iceberg. Beneath the water line the hidden benefits begin to pile up. Employee moral improves, process organization and efficiency increases. Employee awareness from a EMS seeps into employee's home lives furthering green living.  These combined activities begin to make an larger positive impact on society. This eventually trickles down to economics, meaning that the positive cumulative effect of pollution prevention contributes to keeping costs to taxpayers low.

An EMS is the guide organizations should use to trigger constructive environmental thought. For example, 14001 clause 4.4.7 Emergency Preparedness and Response is meant for an organization to consider the environmental impact that can be caused from an emergency or natural disaster. This is not a normal consideration that would not usually be made.

The standard requires that employees understand the aspects and targets the organization is trying to obtain. Most importantly, they require that employees and contractors understand the consequences of their departure from specified procedures or operational controls.

Of course the EMS has the same customer benefits in the marketplace as ISO 9001QMS does.  Customers will ask and require a certified EMS more going forward. Having an EMS is a case of "sustainability".

Does implementing a Process Based Management System put my job at risk?

Recently while working with some students in a Lead Auditor class for ISO 9001 one of the students came up with a serious concern about his being committed to ISO 9001! His questions was “With a  well-documented Process Based Management System (PBMS) in place everyone will know what I do. So how can I then ensure the security of my job?”  Over numerous classes that I have taught, this question often comes in one form or the other. This is particularly relevant when I work in other countries where jobs are hard to come by. I am sure there are others who have this job insecurity as their  company begins the process of implementing a PBMS based on a standard. Their worry is “what is in it for me?”

Clause 5.5.3 of the ISO 9001:2008 requires the management to ensure internal communications with regard to the effectiveness of the quality management system. These internal communications must explain and address the doubts of the employees. The employees must appreciate that a bad system can let down the best man every time. Without a system the blame culture will prevail and overall efficiency be adversely affected. Management will then invariably ask “Who?” – meaning blame the employee, instead of asking “How?” and or “Why”- meaning how and why did the system let down the employee. In real terms with the system the blame moves from the individual to the system. Even if the employee’s incompetence caused the deficiency the system failed in terms of ensuring competence either by incorrect hiring, or training or continued education and so on. The organization should improve the system which placed an incompetent employee in a position where he/she could not perform, instead of blaming the employee. Disheartened employees are the result of being always blamed for poor work and the results, leading to the work environment (clause 6.4) not being congenial for achieving product conformity. How can any organization achieve continual improvement (clause 8.5.1) if deficiencies are not addressed.

Employees often forget that their job security is dependent on the organization constantly improving with the continual improvement cycle to be productive and viable. Without the improvements the organization itself will go out of business and so the jobs will be lost. Investing in a system approach and addressing deficiencies by corrective action(clause 8.5.2) can against the recurrence of non-conformities. As the data base builds and the employees can get the information from the data and analyze it (clause 8.4) can they predict potential NCs (clause 8.5.3) and so add value and therefore sustain the organization to enable the organization to continue to meet the expectations of the manpower. After all benefits are an outcome of the “cash in the bank”.

As the PARs (Preventive Action Requests) start coming in and the employee participation increases the system stabilizes creating the environment for innovation. The organization immensely benefits from innovative products (story of Apple is a case in point) and is therefore able to pay its employees better. A system approach therefore not only is an investment in retaining the employees (job security) but a sure way to ensure better future prospects. The success of the organization then contributes to the well-being of the society and the ultimate prosperity of the nation. We could stretch the benefit of the system approach further and say it would meet the futuristic stability too and ensure conduct which is socially responsible (SR). 

Comments on CEO Transocean admitting to mistakes related to the tragedy of Deepwater Horizon

In a recent article in the Maritime Explorer, "Transocean Ltd. CEO Steven Newman said the company’s crew on the Deepwater Horizon “should have done more” to prevent the rig’s 2010 explosion in the Gulf of Mexico". http://www.maritime-executive.com/article/Transocean-Should-Have-Done-More-Before-Blowout-CEO-Testifies-2013-03-20/

This is indeed a pleasant change and in a way a pioneering effort for which Transocean's CEO needs to be congratulated. The maritime industry, in general, avoids taking blame. There are reasons for that wherein for example P&I clubs do not really pay unless someone is blamed. A bad system will defeat a good person every time” – W. Edwards Deming.  This reminds me of a quote from the Cain Mutiny, which in essence says, “Navy is a master plan devised by the genius for execution by idiots”.  This master plan is the system, which should be so created that there is no need to blame the individual.  Every time the system fails, the management reviews and acts to work on the procedures that comprise the system.  Improve the system enabling better protection of the individual. It is ironic that individuals who are assigned the designing and then implementing of the system often consider it a burden – little realizing that the system approach takes management away from asking, “Who” to asking, “How and Why”.  This results in further development of the system rather than blaming the individual who was simply working within the system.

In this article, however,the CEO talks of both good people and a good system. I agree with the good people bit. In any case if analysis reveals that the employees lacked competence or were negligent it would again point to the system, meaning the weak HR (Human Resources) procedures which hired incompetent personnel. So it is always the system which lets down the organization. So my objection and suggestion to Transocean (for that matter any maritime organization) is not to say that their system too was “wonderful” but to re-look at the system and analyze how the system let down the personnel they selected. I have a quote which I use when I work with organizations as I develop their systems as a consultant and that is “the only bad NC (Non Conformity) is the one you do not know about”. The system therefore should be created with the environment matched to encourage NCs to be reported. After all corrective action and correction are NC driven. And as the NCs collected contribute to the data base increase, they will provide the information which can be analyzed and trends obtained to predict potential NCs. The company becomes a mature organization when it can predict potential NCs before they occur. Potential NCs are data driven. Therefore Transocean needs to work towards that end. So, yes the CEO has indeed taken a very positive step by accepting the deficiencies and will no doubt now look ahead to going back to the Plan stage of the P-D-C-A cycle (Plan Do Check and ACT) and review the system.

Stop Work Authority and the ISM Code

A QMII alumni recently sought my opinion in interpreting the ISM Code with an interesting question.  I am sharing my reply in generic terms for the benefit of my blog readers:

Does the ISM Code refer to a policy to Time Out For Safety (TOFS) or Stop Work Authority (SWA)? A reference of the same to the ISM code being implied by the the United States Department of Justice

A stop work policy basically requires any crew member on board to self-assess and if he/she feels an operation is unsafe the crew member can stop it until further investigated and cleared by the safety officer/TM. Although there is no specific mention of a stop work policy in the ISM Code, it has its genesis in Clause 1.2.2.1 and Clause 2.1 of the Code. In interpreting the ISM code implementation from the company point of view the objectives & functional requirements are squarely the company responsibility. If a company has any doubts about the implementation of any policy likely to result in a lapse, it is imperative that it make policies which clear this doubt.  

Clause 2.1 in the tail end carries the sting asking “…how the objectives given in paragraph 1.2 will be achieved”.  It is thus, in my opinion, incumbent upon the company to provide a policy on and encourage the  stop work policy requirement to ensure the safety of operations and a safe work environment. 

I may add that, in general the ISM Code in itself is brief, flexible and open to interpretation by the company and Flag State. IMO itself in Resolution A.1022(26) provides the guidelines on interpreting the Code. These must be read in conjunction with the code. In the introduction to the Resolution paragraph 3 requires the Administration to ensure companies amplify on clause 1.2. The next paragraph requires the “development of a safety culture…” implying amplifying instructions, as for example TOFS, should be provided by the company.

As companies mature to the development of the safety culture by welcoming NCs (Non-Conformities) as the driving factor for Correction and Corrective Action (based on RCA- Root CauseAnalysis), the interpretation of the clause 9.2 of the ISM Code requiring “measures intended to prevent recurrence” would necessitate the culture which again encourages the stop work policy.