ISO 14001 Clause 4.4.2 - When do I need a procedure?

[Al the Elf]

I'm looking for some guidance.

I'm rebuilding our Management System from the ashes of a "Certificate on the Wall" ISO900x:1994 approach, and we are now also addressing ISO14001 and OHSAS18001 in an integrated management system. One of the releases to my management team has been the removal (in ISO9K:2K) of the formal requirement to have "a written procedure for...", and with gusto they are comfortably defining auditable "processes".

My problem is this - ISO14001 for example in Clause 4.4.2 says "It shall establish and maintain procedures to make its employees or members at each relevant function and level aware of .....", but in keeping with 9K-2K I have no procedure, but I do have a bunch of processes.

I'm interested then in how auditors are interpreting this (and all other places where 14001 and 18001 still refer to procedures when 9K-2K requires a process) with regard to accreditation.

Simply - if I have an auditable "process", but don't have a "procedure" will I be unsuccessful in registration to 14001 and 18001 ?

Cheers, Al.

[Randy]

There are only a few written procedures required by the standard. If the standard doesn't require a wriitten procedure then it is the organizations right to determine its approach. To me in the absence of a written procedure, if everyone knows what to do and when to do it and how to do it, you're covered. Process and procedure are at times synonymous. IMHO

[goose]

Following up to what Randy said if "it's not documented you might expect an auditor to interview several participants in the process to determine that the process/procedure is consistently beig followed".

In absence of a documented procedure you may want to have good records of training on the methodology used.

The voice of gloom returns.

Although a procedure is not required by a standard does that mean you should not have a procedure?

Procedures need to be written and enforced based upon the dynamics of the organization, including work force knowledge.

Who uses level II procedures?

The Management Representative to cover the companies ass.

Who uses level III instructions and forms?

The entire company from the president down to the lowest level of employee. These are the most impotant aspects of a working management system. Instructions give people to knowledge (on top of training) to perform their jobs in the correct manner.

Take it from the lowest to highest personnel in an organization. Even the President or G.M. needs an instruction as to what needs to be accomplished to cover manufacturing/quality requirements during management review.

And believe me, the worst cases of not following procedure/instruction are from upper management that should know better.

Working people want to do the job the correct way, if management does not give them the tools and training, all is for nought.

To all Quality Proffesionals out there I ask you to respond to the following question:

When was the last time your corrective action said "operator error"?

Sorry, my typing fingers (left fore and right middle) are getting tired. I really would like some response!

[Jim Biz]

Saddly (I hate to admit) -- the last time was this morning...
ARRRGH ...

How long do you suppose it will take to get everyone on board ?.... Operators don't make "errors" - they are management controlable issues and can be avoided.

Regards
Jim

[Al the Elf]

Thanks for the feedback folks -

The feeling I'm getting is that at Level 2, I can probably appeal to the auditor that I have a clearly defined process (flowchart, training, etc), and they aren't going to hold me to the letter of the (14K, 18K) standards to force me into having a written procedure. Provided, of course, I can demonstrate in the field that people know what they are supposed to be doing, and are then compliant with it. Has anyone experienced auditors who take the hard line view ?

I agree with Al on Level 3 documentation, and it's criticality. We're getting quite comfortable on "Operator error", although it's frequently the easy cop out from really understanding a root cause. With a customer interested in short term cost constraint, it's often the most appropriate answer.

Cheers, Al.

[Randy]

I tell you Al the only way I can hold an Auditee to have a written procedure is either:
1) It is required by the standard
2) They have a document that states they will have a written procedure for whatever
3) The absence of one could lead to deviations from policy and the objectives & targets (4.4.6).

I think (me, Randy, a unit of one) if folks do the job they way they say they will and it can be verified, they don't need don't kill trees to just get a warm fuzzy. Flow charts, if accurate, are worth a thousand words, so are level 2 docs. IMO

[Marc]

Originally posted by Al Dyer

Who uses level II procedures?

The Management Representative to cover the companies ***.

I have never worked with a company where only the Management Rep used level IIs, nor can I imagine such a company unless it is very, very small.