Is not having EMS manager for 6mo a root cause for items not being done?

[liller]

Hi all,
Thanks for all the great advice. I work as the EPM for a seasonal business. Last fall the old EPM quit after our initial cert and I did not come back until the beginning of the season to sort out everything. So everything we said last season that we were going to do, we didn't do. Digging deeper and deeper and a result of internal audits, I am finding a lot of items were not done, ie.. documents not being reviewed, not keeping up with objectives, targets, action plan etc.. We have come a long way on our obj and tar. It makes no sense operationally to review job descriptions, training matrices now, as we only have one month and those should be done during the off season. I am trying to cover myself by using the corrective action process for documents not being reviewed and such with the due date this winter. Will this work? Our tranisition audit in a month.

Is not having winter EMS continuity a root cause for items not getting done?
This is how I feel :mg:

Thanks for your help,
The Liller

 

[Randy]

Major NC here and possibly a few more based on what have stated...the system shall be MAINTAINED!!! Read 4.1 and 4.4.1....really read!

Also take a gander at 4.2 (the committment part) and 4.6 (your management needs to be hammered cause they ain't doing their job)

As for doing things during the off season my response is "Why are you wasting resourses at all (time & money) if the EMS is something you do only when you have time to spare?

If you have a Registered system your next surveillance may be real fun if you get an honest auditor.

If your business depends on the system being in place due to customer requirements there may be some issues there.

If you're a publically traded company and your EMS was factored in as part of the value of the company then there may be some S/O issues because of risk and disclosure.

Lot's more if's, if you want 'em.

 

[BSMITH]

Problems

I think your real question is strategy; what do you do now?

It sounds like right now you don't have the resources to improve the EMS at least back to where it was during your last audit. You can either risk the real possibility of multiple major nonconformances or acquire EMS assistance from a consultant (no, I'm not drumming up business) or an employee with EMS experience from another part of the organization or another facility.

 

[RoxaneB]

I'm with Randy on this. Where was the designate...or designates to run with the ball? If the big boss in the corner office had suddenly quit, would your organization stop running? Of course not. Yes, things would be a little stressful and leaner in his/her absence, but you would continue to operate.

The same approach should be taken with the EMS....or any Management System for that matter. There should be back-ups to carry out processes in the absence of the person who usually performs the task.

In your case...there should be people who understand the document control process, people who understand how to verify and validate objectives and targets are met, people who understand how to address abnormalities within the processes and system. It should not fall to one person to address all of these items. The Environmental Rep or Manager should coordinate such activities, but not be the one to fix every flaw that occurs.

Is there a problem with your system? My honest opinion is yes. As Randy said, management committment doesn't appear to be there and that is a major factor in the maintenance of a system. How can you improve the system if it's not even maintained?

All that negative said, BSMITH brings up a very good point. Now what? You've acknowledge the flaw....what do you do? I'd put together a plan that outlines how each "hiccup" that occurred during the absence will be addressed or was addressed. I'd also put together a plan to train some designates and remind management of their committment to the environment and the management system.

As an auditor, I'd be extremely worried to see such a gap in the system for such a prolonged period of time....however, I'd be extremely happy to see some actions plans developed (and hopefully some actions concluded) by the time I visited.

 

[IEGeek - 2006]

If I have commented once, I have commented 100 times. A lot of companies just want that pretty piece of parchment with calligraphy in the lobby to say to their customers, "Hey, look we did what you required us to do."

If your company wanted a "Paper Tiger" then you have succeeded. If you wanted a truly environmentally friendly company, you have failed miserably. I agree with Randy and RCBeyette 100%.

For the future, I would recommend that when the EMS manager takes the season off (how do I get that job?) a person be designated that is on-site year round that can manage the system and MAINTAIN it. I question appointing a manager that does not work year round. I question your registrar that thought it was ok. I question the validity of your system.

Good Luck

 

[SteelMaiden]

I've faced similar situations in the past...QMS side only..

If the organization is truly committed, they (top management) would ensure that someone stepped up to the plate and kept the system moving forward. I would not accept "we were without an environmental manager" as a root cause. After all, what happened to providing resources? I know sometimes it takes some time to get the right person, but in the meantime someone needs to keep the train on the tracks.

Good luck, it sounds like you are going to have your hands full. BTW, hopefully, none of the stuff that didn't get done was a regulatory requirement.

 

[RoxaneB]

Is not having winter EMS continuity a root cause for items not getting done?

Hmmmm...doesn't appear that we really answered your question in a direct manner.

Answer = No....not having a winter EMS continuity is not a root cause for items getting done.

Try a few more "Why's".

1. Why weren't items/issues completed and closed out?
No winter EMS continuity.
2. Why was there no winter EMS continuity?
The EMS Manager left the organization and the replacement was not brought back until seasonal scheduling dictated the return.
3. Why was there no interim replacement?
Management did not feel an interim replacement was necessary.
4. Why were responsibilities to address issues not distributed upon current personnel?
????
5. Why do we have an Environmental Management System?
????

Liller, I hope we don't sound or appear too shocked at your situation...our answers probably have not been worded in the most positive of tones. I suppose that we're simply amazed that such an event has happened.

Out of curiousity, how long has your organization been registered? I won't ask who your Registrar is (even though I want to). Of course, if you want to tell us, you're more than welcome to.

Perhaps it's time to approach your management about some restructuring of responsibilites.

An EMS Manager should know the regulations and legislations, but ensure that the appropriate know what applies to them. That way, should your EMS Manager (guess that's you now, right? ) wander off into the vast Alaskan wilderness to shack up with a Kodiak, others won't be left to let the system slide.

When audit results come in, they are initially directed to the EMS Manager who is responsible to ensure that they are re-directed to the suitable people. For example, if I discovered that we were in violation of noise emissions due to bay doors opened outside of normal operating hours (and we were operating under normal conditions), the finding would go to our Melt Shop Manager. If I discovered that proper radiation protocols were not being followed for incoming material, the finding would go to our Raw Materials Superintendent.

We don't know what these dropped issues were but I think most of are assuming that they could (and should) have been addressed by people other than the Environmental Manager.

Please keep us updated on your progress and the results of your external audit!

 

[liller]

Out of curiousity, how long has your organization been registered? I won't ask who your Registrar is (even though I want to). Of course, if you want to tell us, you're more than welcome to.

Thanks for your advice, it has been what I have been thinking but was not sure, I am self taught at this job and it does make me want to crawl into the Alaskan wilderness most days.

It will be one year this coming september that we have been registered. We trying to get certified to the 2004 standard this september. Since we have had this program for less than a year would a corrective action towards winter continuity for top-management work?

I'm just really nervous, our internal auditor training was horribly ineffective last season and this year I don't feel trained as an internal auditor, so to cover that I wrote a preventive action and they are sending two of us to a five day Lead Auditor School after the audit, I hope that works. We had a horrible experience with our consultant last season that we didn't hire one back, I think I can handle it with more training.

Thanks for your help I need a kick in the butt sometimes I need to get over my shyness so I can kick butt here.

 

[RoxaneB]

Thanks for your advice, it has been what I have been thinking but was not sure, I am self taught at this job and it does make me want to crawl into the Alaskan wilderness most days.

For what it's worth, I think a lot of us are self-taught. My first exposure to ISO 9000, was as a summer student in between 1st and 2nd year university. My boss had taken the Lead Auditor course, gave me his manual and said "Read it. Your job is to implement ISO at this plant. You have 3 months." Definately a crash course in ISO...and time management...and stress management.

It will be one year this coming september that we have been registered. We trying to get certified to the 2004 standard this september. Since we have had this program for less than a year would a corrective action towards winter continuity for top-management work?

Would it work with your Registrar? Don't know...it certainly can not hurt, though. Would it work for your system? Yes. You've recognized that the system temporarily fell apart and want to ensure that it doesn't happen again. Such an approach is key to a success system....root cause, action plans, verification plans, etc.

Odds are you can not cancel the audit...but they may let you postpone it for a month or so. If you feel that extra month would be beneficial to addressing the corrective action, contact your Registrar and ask to reschedule. The question I have to the other members of the Cove is how honest should Liller be in explaining the reasons behind the request for a postponement?

I'm just really nervous, our internal auditor training was horribly ineffective last season and this year I don't feel trained as an internal auditor, so to cover that I wrote a preventive action and they are sending two of us to a five day Lead Auditor School after the audit, I hope that works. We had a horrible experience with our consultant last season that we didn't hire one back, I think I can handle it with more training.

Those first few audits are always nerve-racking. After my time of auditing, I've evolved to be merely apprehensive. Not necessarily for myself, but for my newer team members. I worry how they'll do and I have to resist urge to play Mother Hen. Always a laugh since many of my newer auditors are older than I.

Training is good, Liller. Experience is better. Auditor training is a nice safe environment in which to learn and practice some new skills...but the real world allows us to get more creative and effective with these skills.

I'm sure you'll do great!

Thanks for your help I need a kick in the butt sometimes I need to get over my shyness so I can kick butt here.

Is it shyness or is it uncertainty about the job and how to approach management? Strongly suggest you don't go in with the attitude that you're there to kick butt. You're there to help. To observe. To suggest. To help repair. To help improve.

As I always tell my auditors..."Auditing is supposed to be cute, warm, fuzzy, friendly...until you smell blood. Only then do you go for the jugular."

 

[Randy]

I'm just really nervous, our internal auditor training was horribly ineffective last season and this year I don't feel trained as an internal auditor, so to cover that I wrote a preventive action and they are sending two of us to a five day Lead Auditor School after the audit, I hope that works. We had a horrible experience with our consultant last season that we didn't hire one back, I think I can handle it with more training.

QUOTE]

Have me come up to Alaska, I'll train ya!

Hopefully your Lead Auditor course will be conducted by an actual Lead Auditor that can share experience with you.