We have been auditing our quality management system for years.
We are comfortable auditing it. We might even have found some real
opportunities to improve by auditing the QMS. Now, there is a new
challenge. Our company is pursuing this thing called ISO 14001 and
we are developing this thing called an Environmental Management
System (EMS). The question was raised whether we should integrate
our EMS internal auditing with our existing QMS internal audit
program. Our internal auditors are livid! Another management
system has invaded our castle! What are we to do?
This scenario is played out daily around the world. As ISO
14001, environmental management system standard gains acceptance,
more and more companies will attempt to merge their EMS with their
QMS. But should they? If they do, what impact will there be on our
internal auditing program? Let's take a look at the case against
integration, the case for integration, and some tips to make
integration smoother.
The Case Against Integration
Different Requirements
Auditing EMS is a totally different world from auditing QMS.
Although there are many similarities, the differences that exist
are significant. There are major differences in what type of
evidence is available. It is not that auditing EMS is harder,
auditing EMS is just different. The rules are different, what
you are auditing is different, and the requirements are
different.
Different Organizational Rules
The organization's rules for auditing EMS is different from the
rules for auditing QMS. The processes are different and how the
requirements of the standard are met are also different. This
could lead to confusion in development and implementation of an
integrated system.
Liability
Whereas QMS has the possibility of shutting a plant down, EMS
has the possibility of sending someone to jail! That is a big
difference! Auditing the EMS plays a major role in ensuring that
environmental regulations are being maintained and complied with.
There is no real parallel in QMS. It could be catastrophic if the
same lax QMS auditing be applied to EMS.
Separate Registrars
Many companies want to keep their EMS and QMS completely
separate. They will go as far as to have separate registrars. In
this case, the organization clearly will want to separate the EMS
and QMS internal auditing.
Auditor Qualifications
Probably the largest factor in the case against integration
is auditor qualifications. All of the above indicated the EMS
auditors need specialized training that is far different from QMS
auditor training. EMS auditors need to understand the complex
rules surrounding environmental compliance.
The Case For Integration
Each of the above are reasons for not integrating the EMS
internal audits with the QMS internal audits. In many cases, the
reasons listed might make good business sense. In other cases,
they might not make good business sense. Now we will examine
the reasons why an organization might want to integrate the EMS
and QMS auditing functions.
Common Requirements
There are requirements that are common to both ISO 9001 and ISO
14001. Specifically management review, training, document control,
records and auditing. It makes sense to merge these as much as
possible.
Maximizing Resources
In today's business environment, most companies simply cannot
afford to maintain separate auditing resources. Using current QMS
auditing resources to perform, or augment EMS auditing allows
organizations to achieve the impact they need with little
additional resource allocation.
Auditor Qualifications
QMS auditors have valuable experience that can be applied to
the EMS audit. They understand the concepts of auditing, objective
evidence, and issuing nonconformances. They are familiar with
understanding the requirements of a standard and of the
organizational documentation. Their experience can be invaluable
in developing and maintaining an effective EMS internal audit
program. Augmenting QMS internal auditors with trained EMS
internal auditors will maximize the auditor base and provide a
well rounded internal audit program.
Process Control
In many cases, environmental program management activities can
(and are) incorporated with the normal process control. QMS
internal audits already determine the effectiveness and compliance
with established process controls. Adding the EMS component can be
accomplished fairly easily with minimal training for auditors.
When QMS auditors teamed with trained EMS auditors, auditing
process control is greatly enhanced.
Steps for Integration
So the decision is to integrate your EMS internal audits into
your QMS audits. How do you go about it? The following are
some considerations for integrating EMS auditing into
existing QMS activities.
Integration Level
When integrating, the first consideration is at what level to
integrate. For some reason we tend to feel that integration must
be full, or none. Instead, we only need to integrate those parts
that make sense. Many of the EMS requirements are very similar to
the QMS requirements. While a QMS internal auditor may not be
qualified (or competent) to audit environmental compliance, the
same auditor may have a better understanding of management review,
internal audits or corrective actions. These common elements of
either system can be easily audited by either EMS or QMS internal
auditors. This is also the starting point for integration. As the
system matures, the integration level can become deeper,
encompassing more territory.
Auditor Selection
As we integrate, the QMS/EMS will become larger (but smaller
than two separate systems). It will require more resources. This
means auditing will also require more resources. We must be very
careful here, to ensure your auditors are not overloaded. Auditor
selection should focus on the auditing needs as well as the
auditor needs. There are parts of the EMS that certain QMS
internal auditors will feel unqualified to audit. It would be
advantageous to have EMS internal auditors take the lead in these
instances. Remember, integration of EMS into QMS does not mean you
will not need EMS internal auditors. Auditors, regardless of the
management system will have to be qualified and competent.
Audit Schedule
Scheduling an integrated audit can be a bit tricky. Once again
resource management is the key. Scheduling the integrated audit
can be accomplished several ways. EMS and QMS auditors could audit
independently, or together. The organization has full
flexibility to schedule the auditing in a manner that meets their
needs.
Audit Conduct
Conducting an integrated audit is much the same as a regular
QMS internal audit. The auditors will use the same basic methods,
and look for evidence that the system is implemented and
effective. The same audit reports can be used. The primary
difference will be in the checklists. But this is really no
difference because we do not use the same checklist for each part
of the QMS.
Summary:
Integrating the EMS internal auditing into the
QMS internal audit program is not an easy task. It is often
challenged by auditors and auditees alike. In many cases, however
it makes good business sense to integrate what parts are able to
be integrated. Integration, even partial makes both
management systems stronger, more effective and could lead to
lasting continual improvement.