Do we have to MEMORIZE the Environmental Policy?

[SteelWoman]

I'm in an argument/"discussion" with one of our corporate folks who insists that at our other plants ISO auditors are coming through and nailing them because people out on the floor in areas where there are significant aspects do not have our entire Quality Policy statement memorized?! I'm finding this hard to believe. Our policy statement is several paragraphs and fits all the requirements of 4.2, but we keyed on one particular phrase which sort of "sums it up" to ask our people to memorize that. He insists that if they do not "spit out" the "correct" phrases from further down in the policy statement that an auditor will nail us for it.

HUH??? Anybody else had this experience? I keep telling our EMS Mgmt Rep that it's the same as QS, where we have a nice Quality Policy statement, but if we go to a machine and ask an operator about it, he/she is only required to recite the "gist" of the policy and understand how the Quality policy effects his/her job, day-to-day activity. When I read 4.2 it says we must "communicate" the quality policy - I don't see anything about MEMORIZING it?

 

[Randy]

NOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO
OOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO
OOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO
OOOOOOOOO!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!


No! No! No!

You get the message?

Employees should be able to tell how the policy effects them in the performance of their work and how they in the performance of their work have an effect upon the policy. They should be able to stress (or at least mention) the organizations comittment to prevention of pollution, compliance with applicable laws, and continual improvement and their tie-in to their job performance.

I'm an auditor (check my credentials), as are others here like Kevin Lehner, and memorizing the policy and all that other krap impresses me not one bit (pull out one of those goofy policy cards and I may be tempted to make a suppository of it).

An auditor (if he is worth diddly squat) is going to look for employee awareness and understanding not rote recitation of dribble.

Train your employess in such a way as to get them to understand the "why" more than the "what". When employees become aware of the why you'll have greater success of "buy-in" and "ownership"

Is your EMS Rep a braindead EHS Manager or something like that?

 

[Claes Gefvenberg]

I agree. There is absolutley no need for, nor any requirement to memorize the policy word for word. A parrot could do that given the proper training, but it could never ever grasp the intent of a policy.

 

[Dean P.]

I agree with both comments (although Randy was a little more subtle than he usually is).

I have audited several people who have reiterated the policy word for word. Then I asked them, "What does that mean to your job?" Nothing but blank stares. If someone has the policy memorized, it usually raises a flag the other way - they have spent so much time memorizing it for the auditor that they really don't understand what the policy means or why it is in place.

A few years ago auditors (both QMS and EMS) would be happy to hear someone say the 'key points'. Not anymore. They don't even want the key points now, they just want to be sure the person knows what part they play in the system.

And Randy, quit beating around the bush and get to the point next time!!!!

 

[Claes Gefvenberg]

Subtle?

Dean P. said:

I agree with both comments (although Randy was a little more subtle than he usually is).
---X---

Randy? Subtle? Are we talking about the same person? LMAO

/Claes

 

[SteelWoman]

Randy, I ADMIRE your reticence to say what you mean! Also LMAO!

As I said, I'm absolutely in opposition to the belief that memorizing those key points from the EM policy and then spitting them out is the way to go. I agree that it's more important that the guys on the floor understand the concept that their work can impact the environment and it's important to make sure we minimize that in every way. On the quality side I once audited an operator and asked him about our Quality Policy. He pondered the question for a moment and said it meant, "Don't ship no SH#!*" I gave him a great write up - he GOT IT, understood what it meant.

We have a NEW EM Mgmt Rep who is the Environmental guy here and he's pre-disposed to believing every word the corporate Environmental guy says rather than the local person who's been through a zillion audits before. Go figure....

 

[Randy]

I've got a well used 34" Looeyville Slugger (baseball bat to you non-American types) for boneheads that make folks memorize tripe. I train a whole bunch of folks on 9K, 14K 18K and all those other K-type management systems, and without fail I tell them all "Don't memorize nothin". I tell them to learn where to go to find out, how to use their references (doc's and stuff like that), understand the "intent" of the policies and system itself. Folks that are required to "memorize" aren't using their time productively (also they need to get a life).

I posted this just after SM.....

Environmental guy? That figures..... He's probably the typical regulation oriented boob suffering from "Tunopia" (tunnel vission & myopia) who can't see outside the box. I just had an article published in International Environmental Systems Update (by BSI) in which I hammered the "Tunopia" crowd. The article was about OHSAS 18001 but it applies to 14K1 and 9K1 as well.

I've gotten a couple of interesting Emails because of it.

 

[SteelWoman]

I could use the Looeyville Slugger, but I'm afraid I'll be using it on MYSELF in utter frustration with this EMS guy. He keeps asking for my help, but when I give him my thoughts/advice he ignores it. Frustrating. I'm trying to mentally separate myself, remind myself it will be HIS system to defend in an audit, his to maintain, his to train to. That flies in the face of my usual mentality, but I've reached point of no return with being ignored. Part of the issue here is the EMS guy really believes, for some reason, that he can just "cut and paste" the system from another location into ours with a minimal amount of work or effort, so anything I say that requires MORE than a cut & paste response from him gets ignored. Not what he wants to hear.

 

[Randy]

You know there SW, I'm conducting an EMS-LA course right now. In fact today we covered of all things 4.4.1 Roles & Responsibilities......remarkable coincidence isn't it? If the folks I have the pleasure of working with today were to perform an audit of your system, and based upon what you have been saying, the hammer would have the potential of being heavy and hard....most likely directly impacting the EMR and bouncing off who knows where.

I use an additonal slide (among other things) that is not part of the course material (the RAB would stroke out). What the slide says is this:

"The Direction You Look Is The Direction You’ll Go.

The Direction You Go Will Determine The Final Destination You Reach."


The meaning I apply to this is....If you shortcut, try to cheat, make it easy, and don't put forth any effort, what you come up with will be weak, poorly implemented, without substance and doomed to fail a lingering death, gasping as it fades out and used as an example by others as what not to do, or as a reason why it should not be attempted. That's a he-l of a legacy.

 

[Claes Gefvenberg]

SteelWoman said:

I could use the Looeyville Slugger, but I'm afraid I'll be using it on MYSELF in utter frustration with this EMS guy. He keeps asking for my help, but when I give him my thoughts/advice he ignores it. Frustrating. ----X----Not what he wants to hear.

It happens to all of us SW, but you should not, repeat, not go clobbering yourself with the Looeyville Slugger...

Keep being your professional self and giving him good advice (Why not in writing, with copies to those concerned). Hopefully you'll get through to him eventually, and you'll be covering your own backside in the process.

/Claes