Environmental and OH&S Management Continual Improvement

somashekar

Staff member
Super Moderator
#1
Can one claim that maintaining to the set objective is in itself my continual improvement of the E and OH&S management system? Off course this will include identifying and meeting any new or revised legal and other requirement.
How will a certifying body react to this
 
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S

samsung

#2
Re: E and OH&S management continual improvement ... ?

Can one claim that maintaining to the set objective is in itself my continual improvement of the E and OH&S management system?
Of course this will include identifying and meeting any new or revised legal and other requirement.
What I understand from 'maintaining to the set objectives' is maintaining the previously achieved level of EHS performance? If it's so, the answer is certainly NO. Such a claim cannot be accepted since you are maintaining a certain level but not 'improving' beyond that level.

Even if the condition is not static, the important thing a CB would see is whether the objectives set by the organization meet the criteria laid down by OHSAS/ ISO 14001, if they are consistent with the organization's policy, whether appropriate programs are in place and how far the organization succeeded in achieving those objectives/ goals. It's not about 'setting' alone, achievement is much more important and more importantly how they were achieved.

Continual improvement especially in the EHS performance cannot be justified unless there are objective evidences that the organization, through application of a systematic approach (such as PDCA), eventually succeeded in minimizing it's EHS risks.
 

somashekar

Staff member
Super Moderator
#3
Re: E and OH&S management continual improvement ... ?

What I understand from 'maintaining to the set objectives' is maintaining the previously achieved level of EHS performance? If it's so, the answer is certainly NO. Such a claim cannot be accepted since you are maintaining a certain level but not 'improving' beyond that level.

Even if the condition is not static, the important thing a CB would see is whether the objectives set by the organization meet the criteria laid down by OHSAS/ ISO 14001, if they are consistent with the organization's policy, whether appropriate programs are in place and how far the organization succeeded in achieving those objectives/ goals. It's not about 'setting' alone, achievement is much more important and more importantly how they were achieved.

Continual improvement especially in the EHS performance cannot be justified unless there are objective evidences that the organization, through application of a systematic approach (such as PDCA), eventually succeeded in minimizing it's EHS risks.
My situation and other business decisions have been such that it is highly impossible to consider implementation of the best available techniques, as at this time they are not economically viable to me. Keeping this E and OH&S certification is also in itself very important for my business sustainability. Though we have commitment to continual improvement in both the policies, management commits to just be able to maintain the compliance levels on the objective and do best to see that we do not go back. There is also a decision of the top management that in a few years the relocation will take place to a different premises and by then the business volumes are also expected to get more and give good returns.
So here in place of the spiral loop given in both 14k and 18k about the PDCA approach, the spiral is so small that it is more a closed loop than spiral. My commitments to prevention of pollution and prevention of injury & ill health is present and visible in my actions.
What problem will the CB see in my EHS management system that will make them say NO.
 

Randy

Super Moderator
#4
Just apply the definition from 14001 to answer your question

3.2 continual improvement
recurring process of enhancing the environmental management system (3.8) in order to achieve improvements in overall environmental performance (3.10) consistent with the organization's (3.16) environmental policy (3.11)

NOTE The process need not take place in all areas of activity simultaneously.


If what you are doing is anything related to improvement of EHS performance or an improvement within or to your system the answer is Yes.
 
T

tamale

#5
You maintain set objectives for a set period of time and review them with improvement in as the primary objective.
Now, given your situation I think your focus should be on taking small steps. No certifying body can say that you need to invest large sums of money in order to demonstrate improvement. Small reasonnable steps in a context of regulatory compliance and you should be fine. As well your employees will appreciate small and contant improvement over huge leaps, given they understand the company's financial situation.

Tamale
 
S

samsung

#6
Re: E and OH&S management continual improvement ... ?

My situation and other business decisions have been such that it is highly impossible to consider implementation of the best available techniques, as at this time they are not economically viable to me.
I agree with what Temale has submitted. There's absolutely no need for huge investment layouts for achieving continual improvement. As Randy has rightly quoted the standard reference. You can focus on one area with only one objective for each (Env. & safety) but it:
1. has to be consistent with your EHS policy and
2. must result in improving the EHS performance ('measurable results of an organization's management of it's env. aspects/ OHS Risks")

So here in place of the spiral loop given in both 14k and 18k about the PDCA approach, the spiral is so small that it is more a closed loop than spiral.
If it's a closed loop, possibly there's no further improvement in the overall Env,/ OHS performance but somehow the status quo is maintained. This shouldn't be enough to demonstrate compliance to 'continual improvement' unless the circumstantial evidences prove that it's impossible to effect further improvements with the available resources/ technology.

My commitments to prevention of pollution and prevention of injury & ill health is present and visible in my actions.
Agreed but that can't be accepted in lieu of CI. As a minimum, one has to do it in order to maintain the system. Both are legal obligations as well.

What problem will the CB see in my EHS management system that will make them say NO.
Possible common causes for their denial (though I don't predict any of them would apply to your case):

1. You present the improvement trends but the area you are focusing on may not be relevant to your significant impacts, to the key characteristics of your EMS or to the policy itself. e.g.; if one of your significant aspects, for example, is consumption of energy in the manufacturing process, then you should not be concentrating on reducing the energy consumption, for instance, in admin office or canteen lighting system even if you are able to show a measurable reduction.

2. If the data/ results show a constant performance level for last many years,

3. Data from monitoring & measurements were analysed but opportunities for improvement were not identified.

4. If the instances of improvement you present before the CB, were accidentally achieved under exceptional circumstance and there are evidences that it isn't going to sustain.

But one thing in your support - continual improvement doesn't have to take place every year, the next instance could come after, say, 5 years provided you haven't left any opportunity unattended.
 
P

pthareja

#7
Re: E and OH&S management continual improvement ... ?

continual improvement doesn't have to take place every year, the next instance could come after, say, 5 years provided you haven't left any opportunity unattended.
Rightly so Japanese prefer Kaizen, to signify the process/intent to Continual (EHS) Improvement is on.
When the certification cycle is three years the CB would not succeed in verifying as to whether the deployment of Continual improvement was existent or not?

Priyavrat Thareja
 
S

samsung

#8
Re: E and OH&S management continual improvement ... ?

When the certification cycle is three years the CB would not succeed in verifying as to whether the deployment of Continual improvement was existent or not?
Any CB, in my opinion, should be looking for whether a process of CI is in place and it's working the way the organization has planned rather than the results. If the organization plans to achieve the results after completion of CB's 3 year cycle time, it should be OK for them. The outcome would be verified during the next cycle or by the next CB.

Thanks.
 
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