What Corrective Action would you suggest in this instance?

S

samsung

#1
Here's the summary of the problem raised during the recent internal audits:

Organization's target - Replacement of 5% of the fossil fuel (coal) with Bio mass till March'10. (target setting was based on past trends of Bio Mass availability in the locale)

Objective: To reduce GHG emission by way of conserving fossil fuels

Achievement status - 2.7% at the end 2009 of 2010.

Reason for deviation - Poor material supplies due to low rainfall during the year & subsequent price hike that rendered use of this material highly uneconomical as compared to coal.

Current year's target - 5% (subject to availability & cost economics)

My questions:

Under the given circumstances, is it a Nonconformity ? The auditor says it is because the objective wasn't cost savings but Green House Gas (GHG) reduction which is consistent with organization's Environmental Policy commitments.

If you think, he is correct, what are the possible corrective actions that can be taken to prevent it's recurrence ?

Thanks in advance for your valuable inputs.
 
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Jim Wynne

Staff member
Admin
#2
Re: What corrective action would you suggest in this instance ?

This is a good example of the unnecessary confusion caused by differentiating between two words ("target" and "objective") that mean the same thing. If your objective were to reduce contributions to GHGs by reducing use of coal when it's economically feasible, you wouldn't have this problem. You would be able to show that this is what you did--you had a 2.7% reduction in the use of coal.
 
S

samsung

#3
Re: What corrective action would you suggest in this instance ?

This is a good example of the unnecessary confusion caused by differentiating between two words ("target" and "objective") that mean the same thing. If your objective were to reduce contributions to GHGs by reducing use of coal when it's economically feasible, you wouldn't have this problem. You would be able to show that this is what you did--you had a 2.7% reduction in the use of coal.
I was also thinking on the same lines and as a precautionary measure, we now suffixed the current year's target with "subject to availability & cost economics". I argued that the GHG reduction can't be pursued if it's not economically feasible but he is unyielding.
 

Jim Wynne

Staff member
Admin
#4
Re: What corrective action would you suggest in this instance ?

I was also thinking on the same lines and as a precautionary measure, we now suffixed the current year's target with "subject to availability & cost economics". I argued that the GHG reduction can't be pursued if it's not economically feasible but he is unyielding.
If you look at the results strictly in terms of the objective, you succeeded. I know that the standard says that you must maintain "objectives and targets," but you have to be careful not to paint yourself into a corner. I'm also not sure that failure to hit a "target" should be considered a nonconformity if a reasonable effort was made, and there's good reason for not hitting it. If the correction in this case is restating the target, I'm not sure anything significant has been accomplished, or that there's much you can do in the way of prevention other than being careful about how you word things lest a pedantic auditor give you an NC.
 
S

samsung

#5
Re: What corrective action would you suggest in this instance ?

If you look at the results strictly in terms of the objective, you succeeded. I know that the standard says that you must maintain "objectives and targets," but you have to be careful not to paint yourself into a corner. I'm also not sure that failure to hit a "target" should be considered a nonconformity if a reasonable effort was made, and there's good reason for not hitting it. If the correction in this case is restating the target, I'm not sure anything significant has been accomplished, or that there's much you can do in the way of prevention other than being careful about how you word things lest a pedantic auditor give you an NC.
Thanks again Jim. This gives me enough support to defend my stand even if an NC is raised by a CB auditor. Although it was an internal audit issue, I want to make sure that things are in the right direction and there's nothing else that one could have done (or should do now) other than, as you pointed, being careful with words in future.

Thanks.
 

Randy

Super Moderator
#6
Re: What corrective action would you suggest in this instance ?

This is a good example of the unnecessary confusion caused by differentiating between two words ("target" and "objective") that mean the same thing. If your objective were to reduce contributions to GHGs by reducing use of coal when it's economically feasible, you wouldn't have this problem. You would be able to show that this is what you did--you had a 2.7% reduction in the use of coal.
Here's where lack of competence in a specific field makes one incorrect and could get others in dutch with a CB.There is a very great deal of difference in an objective and a target in this case (we're looking at environmental stuff here) establishing and meeting documented targets is necessary to achieve documented objectives.

ISO 14001:2004 - 3.9 environmental objective
overall environmental goal, consistent with the environmental policy (3.11), that an organization (3.16) sets itself to achieve

ISO 14001:2004 - 3.12 environmental target
detailed performance requirement, applicable to the organization (3.16) or parts thereof, that arises from the environmental objectives (3.9) and that needs to be set and met in order to achieve those objectives


Now samsung here's the real deal....If you had to change your objective, target of both because of cost, availability of the energy source or even if you realized as an organization that you couldn't achieve it then there is no problem if it is either reflected as an internal corrective or preventive action. They are your objectives and your targets and you can change them as necessary to reflect changes that may effect your operation, business, finacial situation, views of interested parties or whatever in line with what is stated in 4.3.3

Your objectives and targets must always be in line with your policy commitments and continual improvement (that's in 4.3.3 also)
 

Jim Wynne

Staff member
Admin
#7
Re: What corrective action would you suggest in this instance ?

Here's where lack of competence in a specific field makes one incorrect and could get others in dutch with a CB.There is a very great deal of difference in an objective and a target in this case (we're looking at environmental stuff here) establishing and meeting documented targets is necessary to achieve documented objectives.
You might have missed it, but I did acknowledge the fact that 14001 differentiates between targets and objectives, but that fact--the differentiation--doesn't affect the probity of my responses, "competence" notwithstanding.
 

Randy

Super Moderator
#8
Re: What corrective action would you suggest in this instance ?

You might have missed it, but I did acknowledge the fact that 14001 differentiates between targets and objectives, but that fact--the differentiation--doesn't affect the probity of my responses, "competence" notwithstanding.
Yep, I believe so, I missed that post and humbly apologize for the mis-step
 

somashekar

Staff member
Super Moderator
#9
Re: What Corrective Action would you suggest in this instance ?

Here's the summary of the problem raised during the recent internal audits:

Organization's target - Replacement of 5% of the fossil fuel (coal) with Bio mass till March'10. (target setting was based on past trends of Bio Mass availability in the locale)

Objective: To reduce GHG emission by way of conserving fossil fuels

Achievement status - 2.7% at the end 2009 of 2010.

Reason for deviation - Poor material supplies due to low rainfall during the year & subsequent price hike that rendered use of this material highly uneconomical as compared to coal.

Current year's target - 5% (subject to availability & cost economics)

My questions:

Under the given circumstances, is it a Nonconformity ? The auditor says it is because the objective wasn't cost savings but Green House Gas (GHG) reduction which is consistent with organization's Environmental Policy commitments.

If you think, he is correct, what are the possible corrective actions that can be taken to prevent it's recurrence ?

Thanks in advance for your valuable inputs.
The Objective is directly in line with the Environmental policy ...:agree1:
The target of 5% for 2009 was based on good assessment of availability of required alternate resource... :agree1:
Achieving 2.7% while looking at 5% has indeed made progress towards meeting the intent of your E policy ... :agree1:
Now I still will look to meet my E policy in 2010 and having studied and assessed the alternate resource I will re-set my objective to meet say 4% as against my optimistic target of 5%.
I will continue this into 2010 and see where I am and what is the status of alternate resource as 2011 approaches. (I may even exceed the 4% that I have re-set)
If it looks promising (meet and exceed) I will go back to 5%, if not I will strive to touch and keep at 4% atleast.
ISO 14K provides for objectives and targets to be planned and to be in line with business objectives and economic dynamics.
Let the internal auditor learn what the ISO 14K opening pages says.
There is nothing more to prevent here, and you are already doing and prevening what you have best planned as your objectives and targets which is in line with the E policy.
Why is the auditor here thinking of the word "cost saving" ?
 
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S

samsung

#10
Re: What corrective action would you suggest in this instance ?

Now samsung here's the real deal....If you had to change your objective, target of both because of cost, availability of the energy source or even if you realized as an organization that you couldn't achieve it then there is no problem if it is either reflected as an internal corrective or preventive action. They are your objectives and your targets and you can change them as necessary to reflect changes that may effect your operation, business, financial situation, views of interested parties or whatever in line with what is stated in 4.3.3

Your objectives and targets must always be in line with your policy commitments and continual improvement (that's in 4.3.3 also)
:agree1: Yes, I perfectly agree and am sure the auditor would now yield. One thing I forgot to mention that as a part of Risk mitigation (though I won't call it a CA), we have now started working on finding alternatives for using other permitted 'alternative fuels' (non-fossil ) such as shredded tyres, paper waste etc., the availability of which is less monsoon dependent.

Thanks.
 
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