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Clause 0.4 of ISO 9001 and EHS - Where should I stop the inclusion of EHS in my QMS

L.Soad

Starting to get Involved
#1
Good afternoon everyone,

I remember seeing some post about clause 0.4 a few days ago, but can’t find it, so I’m creating a new discussion. Clause 0.4 states that:
ISO 9001 2015 said:
This International Standard does not include requirements specific to other management systems, such as those for environmental management, occupational health and safety management, or financial management.
The question is pretty large: Where should I stop concerning the inclusion of EHS in my QMS ? I already identified it as one of my companies’ process (should I put it completely out of the scope of the QMS?). As we go on client sites to do our job, and because it is a pretty dangerous job, I think it’s at least mildly important to put EHS into our QMS. What kind of client would not be bothered if a subcontractor got seriously injured (or died) in their factory?

thanks for your feedback.

Soad
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#2
Where should I stop concerning the inclusion of EHS in my QMS ?
The issues surrounding employee health and safety are part of the occupational health and safety management system. Why would EHS be part of a QMS? Is your financial system part of the QMS?

The organization has to balance and manage multiple disciplines in order to achieve sustainable growth. The EHS is part and subset of the business processes. That's why the ISO HLS has 5.1.1c) in all of it's management system standards. It is wise to integrate all relevant disciplines into a coherent, well aligned business system, but quality is the part of the business that deals with product conformity and customer satisfaction. Sometimes quality and EHS clash, sometimes they go hand in hand; proper balancing is required.

In the example that you offered, a technician performing work at your customer's site will be exposed to a number of occupational hazards for sure, and that needs to be managed, without a question. Likewise, his/her work might impact customer's satisfaction and the environment. So, the conclusion is: when you have an employee performing work at the customer premises, multiple issues have to be properly managed. Multiple disciplines are at play. Why do all of them should be part of the QMS? They aren't. My recommendation? Manage the activity and processes for all of the exposures, in a coherent manner, but don't try to make EHS a "part" of the QMS.
 

L.Soad

Starting to get Involved
#3
I guess i've been too zealous in my process map conception, that must be a common error for rookies. Yes, i've also got a financial part in my QMS. Its really not a big thing, just a few really short documents. It covers client billing, supplier payment, etc...

Guess i have to delete them too. It will save me some time and efforts, but somehow i feel i'll be missing something in my QMS.

Thanks Sidney
 

L.Soad

Starting to get Involved
#4
Hi!

Little update: I’m going to cut EHS management, even though my boss wanted to have an integrated management system with EHS in it (maybe in the future when I’ll be far away !), and «financial system» of my QMS.

Do I just need to state in the scope of the QMS that these activities are not concerned (it would be documented, as 4.3 states)? Or it’s not even needed? Right now, I have a quality manual, I now it’s not required any more but I kind like it because it centralize a lot of information in one place, and it would just be like 2 lines added.

Thanks
 

Tagin

Quite Involved in Discussions
#5
Especially since it is a prominent aspect of the operation of your company ("it is a pretty dangerous job"), I don't see any reason to exclude it from your QMS. If your EHS is documented and managed separately, then your QMS really just needs to refer to that other system, the authorities/responsibilities, etc. and to make sure the EHS system has appropriate document control, training records, and such.

Likewise, I agree that financial is reasonable to include, at least to the extent of customer touchpoints, communications, & satisfaction, and likely include supplier financial payments/agreements processes, even if only high-level. Control of financial risk (e.g., who gets NET terms?, how are credit limits set/managed?, etc.) seem entirely reasonable to include.

What I think 0.4 refers to is that 9001 is not about compliance to requirements for other EHS, financial, etc. management systems. That is, it is a disclaimer that 9001 does not per se include EHS or financial requirements. To me, that disclaimer does not automatically translate to a license to exclude EHS or financial processes from the QMS. As such, a 9001 audit would not be auditing your compliance to an EHS standard; but rather, whether your EHS processes are compliant w/9001 requirements, just like any other process in your company.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#6
Do I just need to state in the scope of the QMS that these activities are not concerned (it would be documented, as 4.3 states)? Or it’s not even needed?
Having an integrated management system where all relevant disciplines and interested parties are being taken into account is the ultimate goal. The scope of the management system(s) should always be properly defined, and, in the case of an external audit, you must ALWAYS remind the auditor that their audits also have defined scopes so they must not audit out of their bounds.
 

L.Soad

Starting to get Involved
#7
Especially since it is a prominent aspect of the operation of your company ("it is a pretty dangerous job"), I don't see any reason to exclude it from your QMS. If your EHS is documented and managed separately, then your QMS really just needs to refer to that other system, the authorities/responsibilities, etc. and to make sure the EHS system has appropriate document control, training records, and such.
Our situation in H&S is kinda weird, due to the origins of the company and the fact it grew too quickly. We have 2 «half time» EHS coordinators, almost never at their desks because they also are operators... I think for now I’m going to refer to EHS management as managed outside of the QMS, it could be integrated later.

Control of financial risk (e.g., who gets NET terms?, how are credit limits set/managed?, etc.) seem entirely reasonable to include.
Everything is so... undocumented. You want to know the answers you asked, you have to ask our financial director (which is also our HR...), and she'll say that it depends (and it can change quickly), and that she knows, so it’s ok... For the moment, the procedures I have on the finance subject are just a written form of «it depends», because I can’t get a better answer, and compiling info for our 600+ customers would likely be a 2 weeks job.

The scope of the management system(s) should always be properly defined, and, in the case of an external audit, you must ALWAYS remind the auditor that their audits also have defined scopes so they must not audit out of their bounds.
Indeed, I’ll make sure to keep an eye on that when the time of external audits come. I’ll also review the scope of the QMS and make sure there is no ambiguity.

Thank you for your answers
 

Tagin

Quite Involved in Discussions
#8
Everything is so... undocumented. You want to know the answers you asked, you have to ask our financial director (which is also our HR...), and she'll say that it depends (and it can change quickly), and that she knows, so it’s ok... For the moment, the procedures I have on the finance subject are just a written form of «it depends», because I can’t get a better answer, and compiling info for our 600+ customers would likely be a 2 weeks job.
Well, it could be something like:

"The Financial Director has authority and responsibility, using their experience and expertise, to:
  • determine and monitor credit terms and limits of customers
  • direct accounting personnel in their day-to-day task assignments
  • escalate financial issues to owners/top mgmt
  • etc., etc."
The idea being that there is control and oversight, albeit in a "non-algorithmic" manner, which alleviates your need to try to document non-existent step-by-step procedures. :)
 

L.Soad

Starting to get Involved
#9
I'll do that Tagin, and do the same for EHS, for now.
I'll try to integrate EHS into the IMS after first certification (if i'll stay). I definitly have more problems to solve before (example: 8.3...)
 
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