ISO 14001 Clause 4.2 - Developing an Environmental Policy

[Randy]

4.2 Policy

OK Guys give me some feedback. This is a question and the actual answer I got back from Top management.

1. Describe your role in the development of the environmental policy. (4.2)
"Quite honestly, I was not involved in the establishment of the policy."

Are there any problems here?

 

[Marc]

Who IS 'Top Management'?

Ah! A trick question! :thedeal:

This needs to be linked to some "Who Is Top Management?" threads. I'll see if I can look one up later. I'm getting ready for my Salt Fork trip.

 

[Kevin Mader]

Randy,

I have to admit, I am not surprised: evidence of the absence of knowledge and know-how.

How is it that folks like this get so far up in an organization? It is a pure embarrassment to the organization to have folks like these in key functions. What is worse, what else don’t they realize they are supposed to be doing?

In my experience, these are the folks who run a healthy organization into the ground in record time!

Regards,

Kevin
& &

 

[Al the Elf]

Depends....

Randy - my obvious thought would be that it depends on what else you find :

I'd want to see if the activities in the organisation (within the scope), match up to the Environmental Policy. Most particularly is there any evidence of activity managed by the Top Manager, that clearly takes no account of the Policy. Does the Top Manager know what the policy is about - can they even find it !

Some other thoughts :

Is it acceptable for the "Top Management" to allocate tasks to individual members of the Top Management team ?
Is it acceptable for them to establish a project group or employed individual to come up with and implement a policy ?
Is it acceptable for them to sub-contract this ?

I guess the answer to all three is maybe ! Provided the Top Management demonstrate some form of ownership.

I guess the non-verbal communication in the way with which your "Top Manager" made his admission would be the strongest hint of all, as to if this organisation had a real Environmental Management System, or just a Certificate on the Wall approach.

My final thought is how many of us really pay attention to the Policy statement - how critical is it. How many policy statements are packed with platitudes about comply with the law, be the best, save the whales, etc. Our Objectives/Targets are far more important to us, as only when we get to these do we start creating something that provides true direction to our actions. I'm sure the value of policy statements has been well discussed elsewhere in the forums.

Randy - it would be interesting to hear what else you found in this organisation...

Cheers, Al.

 

[Kevin Mader]

Hello group.

Al posted some thoughts that stirred my brain a bit.

Al posted:

“Some other thoughts :

Is it acceptable for the "Top Management" to allocate tasks to individual members of the Top Management team ?
Is it acceptable for them to establish a project group or employed individual to come up with and implement a policy ?
Is it acceptable for them to sub-contract this ?

I guess the answer to all three is maybe ! Provided the Top Management demonstrate some form of ownership.”

I would have to say that this in my mind in not a “maybe” but a definite “No!” My reason for this is that the establishment of policy in my mind cannot be delegated to a lower level. It must be established by those in Top Management. In reality, someone from a lower level can possess the knowledge and know-how that those in Top Management lack. In this case, this person could educate Top Management of why a specific vision, mission, quality policy is meaningful. Still, Top Management must act on their understanding of the information presented and lead. I think this is what Al meant in this last line of the quoted portion above. While a lower level individual suggested a course, it is Top Management who will lead. Al, please correct me if I am wrong in my interpretation.

Unfortunately, what usually happens is that Top Management will delegate away responsibilities that are their own but seldom with the necessary second ingredient – authority. The person is set up for failure despite their eagerness to ‘rise to the occasion.’ Ownership requires both. How many of us in middle management are given true Ownership? Few.

Finally, the importance of an AIM, vision, mission statement, or Quality Policy cannot be underestimated, although to Al’s point, it is. What is it that we are in business to do? How can anyone in the company identify their work with the AIM if they don’t know what either one really is? They cannot despite their valiant efforts. They are frustrated. It should be no mystery as to why organizations struggle and fail– they lack the knowledge and know-how of what they are in business to do.

Just an opinion.

Best regards,

Kevin

 

[Al the Elf]

Kevin said "While a lower level individual suggested a course, it is Top Management who will lead."

- I absolutely agree, and that was what I mean't in my previous post. I was interested in the non-verbal stuff from Randy's Top Manager, as in my experience it would quickly tell me if :

"Quite honestly, I was not involved in the establishment of the policy."

means

I have no buy in to the policy statement, and will disown it as soon as someone pushes me, it appears to be costing us any money or it actually changes anything round here.

or

I've endorsed the work of my professional team, and now feel ownership of the policy.


I kinda disagree on the other point. I've always felt it is the actions of all the managers, cascaded from the Top, that set the tone for what we're doing rather than the Mission or Policy statement. In my organisation it's a bit obvious that we're hear 'to make chemicals that satisfy customers, without injuring anyone' - it's implicit in coming to work for a chemical manufacturing company. Perhaps if the organisation has a less clear purpose, or radically changes direction then a policy statement may help, but I haven't encountered one yet.

Cheers, Al.

 

[Kevin Mader]

Hello Al,

Here is one for the group: How many organization’s can clearly declare their Purpose?

Ask this question at various levels in the company. How do the answers compare?

Regards,

Kevin

 

[Marc]

The # of different answers will approximately equal the number of persons queried. What does this tell us?

 

[Al the Elf]

As they would in any organisation regardless of how clearly the policy/purpose/mission statement had been established.

Take my simple one : "To make chemicals, to satisfy customers, without injuring anyone".

If you sit and think on this for a moment, you'll come up with all sorts of different perspectives on what this could mean from "only make ethically sound eco-friendly bio degradeable products" to "we'll do anything for money, and flog our workforce to within an ounce of them suing us for physical injury".

The whole general feel of the organisation tells me far more about the commitment (to environmental or any other requirements) than I get from any policy statement; and particularly then, the attitude of the Top Manager in Randy's original post.

Cheers, Al.

 

[Randy]

More 4.2 Policy Questions

OK guys give me some hints here. I'm doing some prep work with a client prior to the registration audit. I'm looking for fresh approaches to these old questions. I have provided some of the answers I have been given. If you have any input I'd appreciate it.

1. Under what conditions would the policy be modified or changed?
Changes in business conditions, products, customers, regulations, or processes could cause us to modify the policy. In addition, we might modify the policy if we identify an opportunity to further reduce bureaucracy or to "raise the bar" for performance.

2. How does the policy help guide business decisions?
The tenants of the policy are considered whenever we make key decisions. From the design phase through production (and ultimately post production support) of our products, the selection of "safe" materials and processes is a critical factor.

3. How does management ensure continued adherence to the policy throughout the organization?
We ensure compliance through regular reviews of key metrics and objectives at the Executive Management Review and daily operations meetings; through an annual review of progress and communication of key areas of focus at our annual -- day; and through the establishment of Key Result Areas which are flowed down throughout the entire organization.

Thanks