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  www.specialtytechnicalconsultants.com Spring 2010  
Fortune Cookie Wisdom: You Can't Ride In All Directions At One Time
Curt Johnson, CPEA, Richmond, TX
Traditionally, management systems lessons have come from books and magazines - and the experts who wrote them.  But if you keep an open mind, you can find inspiration in the most unusual places - like fortune cookies.
 
When implementing management systems, one of the more challenging tasks can be identifying priorities for action.  The planning phase of the environmental management system development process calls for implementing a procedure to identify all of the environmental aspects over which you have control and determining their significance; prioritizing the significant environmental aspects; and, establishing objectives and targets that address those significant environmental aspects.  The parallel occupational, health and safety management system strategy calls for implementing a process for hazard identification, risk assessment, and determination of necessary controls.  Hazards which present an intolerable risk must have objectives in place for controlling or eliminating the hazard such that the risk can be tolerated.  (Note - The balance of this discussion will focus on environmental management systems.)
 
Establishing a system for identification and prioritization of environmental aspects and impacts is relatively straightforward.  Implementing the process can be tedious, however, as a thorough analysis takes time and effort to examine all the organization's activities, processes and services and their associated aspects and impacts.  Conducting the risk analysis or prioritization takes more time and can often initiate plenty of debate on the relative importance of aspects, as well as debate about the process itself. Utilizing the collective knowledge of your implementation team is critical to successfully completing this thorough analysis.  (Announcing to an implementation committee that it is time to review the aspects and impacts analysis often leads to an increased vacation requests and other travel announcements as certain team members try to maneuver out of participating.) Too many managers make the mistake of trying to go it alone, or perhaps deciding that the aspects and impacts analysis does not really have to be re-examined.  There is often a tendency is to believe (hope?) that nothing within the organization has changed and, therefore, no modification to the impacts and aspects is needed.  Conversely, without conducing a critical analysis there is the potential to falsely believe that , you might believe that the current operational controls have worked when, in fact, there are still unacceptable impacts to be controlled.
 
Take the time to thoroughly review your environmental impacts and aspects procedure with your team, even if it is not the first time your organization is examining your aspects and impacts.  Not only do you want everyone understanding how to proceed using the same procedure, if the team has conducted the analysis before, they probably have some ideas for improving the process.  At a minimum, gaining their agreement and buy-in during the initial procedure review can reduce the time spent later debating "how this should be done."
 
Ultimately, the team's objective is to decide what is significant enough to deserve objectives and targets, and the discipline of programs designed to achieve those objectives.  This is where the process can be most challenging.  More often than not, there will be team members who are passionate about the importance of specific issues, and one person's passion does not always align with that of another.  Debate and disagreement can often mire the process and stall progress.  I found some fortune cookie wisdom that can break the tension inherent to these types of debates:

Fortune Cookie

In other words - Choices have to be made or your efforts will become too diluted to make any actual progress.  Utilizing a quantitative process for determining significance will help assure that one person's passion does not unduly influence prioritization of aspects.  Consider a simple comparison of two systems where the following elements are rated in importance 0 to 5 and the values are added for comparison of significance:
 

 

Hazardous Waste Storage

Stack Emissions

Within the control of the organization

5

5

Potential for injury or nuisance to public absent controls

2

5

Relative interest shown by agency via inspections

2

3

Sum =

9

13

 
If the criteria for judging and assigning ratings are agreed upon within the committee at the start, even the most passionate manager concerned about hazardous waste storage would be hard pressed to deny the significance of stack emissions impacts.  While this particular manager might be able to argue that agency interest in both issues was equal, the potential for injury or nuisance to the public by stack emissions is going to trump waste storage.  Once the analysis is complete and numerical values of significance have been determined, there will clearly be issues that are determined to be more significant than others and requiring greater ongoing attention.  (Note that I am not advocating ignoring the hazardous waste storage area, but if it comes down to a question of which system should get limited resources, your analysis indicates that stack emissions impacts should receive resource priority).

During your next implementation committee meeting, consider Chinese take-out for the next working lunch. You might be surprised to find the wisdom needed to keep your management system process on track.

Curt Johnson, CPEA, is a Senior Program Director located in Richmond, TX. He has more than 30 years experience in the development and implementation of environmental, health and safety management systems. Curt is the current author of the ISO 14001: Environmental Management Systems - A Complete Implementation Guide published by Specialty Technical Publishers of Vancouver, B.C. He recently completed a new "Continual Improvement" chapter for this Guide.

Questions about this Article?
Melanie Powers-Schanbacher
Telephone: 908.707.4001