Job descriptions (4.4.1): Management Rep, Document Author, Document Approver

drgnrider

Quite Involved in Discussions
#1
Looking for clarification on the following role definitions, mainly on how an auditor will view them...

- Document Author ? Person who will have direct responsibility for this process/procedure via implementation and/or oversight
- Approving authority - someone who has ?technically reviewed these and says they do conform to company, Federal, and State regulations?
- Management Representative - verifying that the documentation is now under document control, that it meets the ISO standards, and that he now has control. (Since these are regulatory issues, if MR is not EHS, he should not be approving anything. :nope: )

Basically, we have an EHS department of one and a U.S. corporate HQ half-way across the country. We are wanting to keep document approval in-house and not have to send EVERY update for another signature.

Our EHS manager is really the only one who knows the state regulations and thus should be the approver, but since EHS also has responsibility for the procedure, he should also be the author....:mg:

Essentially, our consultants are taking US HQ's docs and scrubbing them for us... so now I am trying to determine the signatures I need on these!!! :frust:

Stressed... Stage 1 in two weeks!!!!! :frust::frust:

Anyone have stock in the whiskey business... how about a kick-back... please!!!! :D
 
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Randy

Super Moderator
#2
Re: Job descriptions (4.4.1): MR, Doc author, doc approver

Job descriptions aren't required, "roles & responsibilities must be defined and documented"

You can define your roles anyway you see fit and it's nobody's business but yours (and it only applies how they relate to your EMS, nothing else)

Signatures? Nowhere in 14001 from 4.1 - 4.6 will you find a requirement for a signature on one single thing including the policy....Requiring signatures is always a self inflicted wound that never escapes my notice

Where does it say that the author can't be the approver? Anyone who approves a doc needs to be competent in the subject matter of the doc...Gotcha there too, because if they don't know the subject how could they approve the content


You're making it too complicated!
 

qusys

Trusted Information Resource
#3
Re: Job descriptions (4.4.1): MR, Doc author, doc approver

Looking for clarification on the following role definitions, mainly on how an auditor will view them...

- Document Author ? Person who will have direct responsibility for this process/procedure via implementation and/or oversight
- Approving authority - someone who has ?technically reviewed these and says they do conform to company, Federal, and State regulations?
- Management Representative - verifying that the documentation is now under document control, that it meets the ISO standards, and that he now has control. (Since these are regulatory issues, if MR is not EHS, he should not be approving anything. :nope: )

Basically, we have an EHS department of one and a U.S. corporate HQ half-way across the country. We are wanting to keep document approval in-house and not have to send EVERY update for another signature.

Our EHS manager is really the only one who knows the state regulations and thus should be the approver, but since EHS also has responsibility for the procedure, he should also be the author....:mg:

Essentially, our consultants are taking US HQ's docs and scrubbing them for us... so now I am trying to determine the signatures I need on these!!! :frust:

Stressed... Stage 1 in two weeks!!!!! :frust::frust:

Anyone have stock in the whiskey business... how about a kick-back... please!!!! :D
It is up to the organization to decide how to meet requirements you are mentioning. No requirment for " documented " procedure. If you are also certified ISO 9001, you shall have a documented procedure for document control and in it you can fix your way to proceed. However the clause 4.4.5 of Document control in ISO 14001 states for a procedure, even if not documented.
For you issue, please check how to proceed with Corporate, because there could be a policy to regulate this.
ISO 14004 proive some guidance for this, you can check.
 

drgnrider

Quite Involved in Discussions
#4
MANY MANY THANKS, Randy...

Job descriptions aren't required, "roles & responsibilities must be defined and documented"

You can define your roles anyway you see fit and it's nobody's business but yours (and it only applies how they relate to your EMS, nothing else)
Not necessarily going to put them in writing, just define a method to our (mainly MY) madness. :confused:
Local management wants ME to be the approver (my knowledge of "Environmental" started when 14001 was thrust upon me four weeks ago) :mg:


Signatures? Nowhere in 14001 from 4.1 - 4.6 will you find a requirement for a signature on one single thing including the policy....Requiring signatures is always a self inflicted wound that never escapes my notice
If no signatures required, how does one prove, per 4.4.5 a, that the documents are ?approved"? Just on the basis that they are password-protected and on our public network where everyone else has "read-only" access? :confused:


Where does it say that the author can't be the approver?
Why I was asking for input from those like yourself. :agree1: :thanks:


You're making it too complicated!
Been accused of this on more than one occasion! :D


For you issue, please check how to proceed with Corporate, because there could be a policy to regulate this.
Thanks, qusys. I am asking them. I also want to have some ?expert? advice on this as their 14001 is ?bloated? with management that has the time for all the paperwork, we don?t. Our EHS is a department of one, I'm not in EHS, but seem to unofficially be classed as EHS's helper when I have time. :thanks:
 

Mikishots

Trusted Information Resource
#5
If no signatures required, how does one prove, per 4.4.5 a, that the documents are “approved"? Just on the basis that they are password-protected and on our public network where everyone else has "read-only" access? :confused:
Your Control of Documents procedure would define how you approve your documents. It makes sense that if the document has been placed onto the public network, it would be deemed released. Just state this, and it's fine.

If it isn't released, it has no business being on a public anything.

So to answer your question above...yes.
 

drgnrider

Quite Involved in Discussions
#6
:thanks:
Thanks everyone for your valuable input!

We decided no signatures. As a technical and regulation review, we will use a comment that 'document has been reviewed and approved by the EHS department'.

The documents residing on the corporate network, password-protected and read-only access, as the access to "approved" documents.

The only document that will have actual signatures is the Environmental Policy. This as a formal acceptance from the factory director and EHS manager that we will be adhering to this policy.

:thanx: time for: :drunk: :beerdive:
 

Randy

Super Moderator
#7
As a technical and regulation review, we will use a comment that 'document has been reviewed and approved by the EHS department'.
That dog won't hunt, I'd ask you specifically (just did it to someone last week in fact) WHO reviewed and approved XXX? And they gave me a specific answer...Guess what? The document related to process waste water management and the reviewer couldn't identify process waste water if he had been drowning in it much less state whether or not the procedure actually complied with the legal requirements. Oops!

Here's the danger and it goes beyond some silly old nonconformity. You're dealing with a highly regulated subject that if full weight of law is used could land not only the company but individual responsible parties in civil and/or criminal court....Right now you're a designated defendant and potential inmate, and so is your leadership. This is something you cannot mess around with lightly.

I started in environmental compliance over 20 years ago in California and you learn fast there. There are some things you do not skirt.

Also, you can have all the signatures you want on the policy, but you will need to be able to prove with supporting, objective evidence that you are in fact working to fulfill it, so in this case I'd ask the Plant Director what the policy means and what he as an individual is doing to help bring it to life.

I'd also be careful of claiming to be world class, or stiving to become world class because you could be asked to quantify "world class"
 

drgnrider

Quite Involved in Discussions
#8
That dog won't hunt, I'd ask you specifically (just did it to someone last week in fact) WHO reviewed and approved XXX? And they gave me a specific answer...Guess what?
:mg: No sarcasm, honesty: what part "won't work"? We have an "EHS department of one" (don't see any changes in the foreseeable future, either) and he is our only subject matter expert (SME) on environmental. He is the one who set these procedures in place (then unwritten) long before we started down the 14001 path and he IS the one doing tech review and approving all of these procedures. I can see this as an issue if more than one person was in the EHS department.


Here's the danger and it goes beyond some silly old nonconformity. You're dealing with a highly regulated subject that if full weight of law is used could land not only the company but individual responsible parties in civil and/or criminal court....Right now you're a designated defendant and potential inmate, and so is your leadership. This is something you cannot mess around with lightly.
:agree1: Absolutely agree!!! Which is why I am trying to avoid my name/signature on any of this, (I didn't even want 14001 management rep), and why I started this topic... the legalities can bite anyone associated with this and I want it ALL correct! This is why I wanted my EHS Manager, as the SME, to be the "Approving Authority" of all of them instead of a VP halfway across the country.


I'd also be careful of claiming to be world class ... because you could be asked to quantify "world class"
:yes: Anyone putting that, or anything similar, in writing is asking for trouble! ;)
 

Randy

Super Moderator
#9
Hey I was a 1 man EHS department for 5 manufacturing facilities located in 4 states and to quote Inspector Harry Callahan "A man has to know his limitations", mine were in air & water management in the different states at the time.

Now back to what you asked, I was incorrect to presume that you had a folks and not individual, but the same statement still holds true, if your department, regardless of the personnel numbers, is lacking in an area of regulatory/media competence, problems could arise during an audit and later...Seen it, done it.

If you end up getting a truly competent auditor and not one that just got grandfathered by passing a test and getting some OJT, your statement could get challenged. I ask about backgrounds, experience, education of EHS professionals at all the EMS/OHS audits I do, especially during a 1st or initial visit....And they had better have someting more to offer than a college degree. Why, you ask? I'll tell you

While conducting an initial Stage 2 EMS audit many years ago I asked the Environmental manager about the organizations TRI reporting and their Form R's. The response I got back was not what I expected (Hint, never ask a question the auditee should not reasonably be able to answer, I'll explain my shock later)....the answer to my question about Form R submissions was "What is a Form R?" ( http ://www. epa .gov/tri/reporting_materials/forms/index.html - DEAD 404 LINK UNLINKED )

Now I couldn't actually explain what a Form R is because of COI and other things but I was able to say " You know, the report forms that have to be filed with the EPA by July 1 each year"....... "When did they start doing that?":frust:

Here's the deal, my auditee/interviewee had previously claimed Masters Degree Environmental Engineering and almost 2 years on the job perfectly qualified them for the position, blah, blah, blah...

To make a long story short, 2 Majors, 1 failure to identify a legal requirement, 1 for lack of necessary competence, no recommendation for certification, and the real biggy...After performing a self disclosure a massive fine from the EPA for failure to file for two years, failure to disclose a state of regulatory non-compliance for permitted conditions, a full blown multi-media EPA inspection that resulted in a couple other NOV's and some personnel housecleaning performed by higher corporate.

So you gotta ask yourself is your SME a SME is all areas or just a select few? This isn't meant to be insulting to anyone, but the SME I encountered didn't quite measure up when needed and catastrophe happened.
 
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drgnrider

Quite Involved in Discussions
#10
This isn't meant to be insulting to anyone, but the SME I encountered didn't quite measure up when needed and catastrophe happened.
:agree1::agree1::agree1: No insult taken. This is why I am asking it here... I get excellent advice from the been-there-done-that crowd! :D :yes:


I ask about backgrounds, experience, education of EHS professionals at all the EMS/OHS audits I do, especially during a 1st or initial visit....And they had better have something more to offer than a college degree.
Our EHS Manager has been at this facility for about ten years and has had the same environmental consulting company, (and same consultant), consulting on all our environmental issues and required programs and reporting. They are also the ones we are consulting with on this process as well. They know our facility better than I do and, I too, have been here for ten years.

Is this a we-know-it-all spiel? Not by any means :nope:. From everything they have been doing with me, (including telling me of required forms that are due), in the EHS Manager's absence, I feel, they have taught him what he needs to know about this facility and how to operate within the state's EPA rules. So I am comfortable he is an SME for our facility.

What can I use on my documents to meet compliance with ISO and regulations when you stated earlier that "signatures [are] always a self inflicted wound that never escapes [your] notice"? ;)
Do I even need a statement saying it has been reviewed/approved? To me this means that anyone could have slapped just anything together.

to quote Inspector Harry Callahan...
:popcorn: :lol:
 
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