Fortune Cookie Wisdom: Adapting to Circumstances in Order to Make Progress

Curt Johnson, CPEA, Richmond, TX

Anyone who has read at least one article or attended even a single training session about implementation of management systems has been heard about the Plan/Do/Check/Act cycle for continual improvement. Discussion of the Plan/Do/Check/Act cycle is as ubiquitous and has become as trite as the fortune provided in many fortune cookies (e.g., "Your fortune and your future are in your hands.")  Sometimes however, the fortune makes it all as obvious as - well, the fortune in your hands.

The Scope of the ISO 14001 Management Systems Standard laid out in Clause 1 states that the standard is applicable to any organization wishing to "establish, implement, maintain and improve" an EMS. The concept of continual improvement appears in five separate clauses of the ISO 14001 standard. With the Scope of ISO 14001 laying out the reason and so many clauses specifically addressing continual improvement, one might expect the process for continual improvement to be pretty simple. However, no matter where you are in your ISO implementation process, the commitment to continual improvement is not easy. But, it is when implementing continual improvement that you can reap the greatest rewards.

During the early phases of agreeing to develop an EMS, you are guaranteed to be faced with someone's concerns about having to agree to continual improvement. The statement will be some variation of "It seems to me that we can only improve so far; once we've reduced our waste or the toxicity of our discharge, we can't just keep reducing it further; even if we could afford it, how can it be better than zero?"  And if you have a mature management system and are in the throes of its management review, there's a good chance that same concern will be voiced again.

So how should you address concerns about committing to continual improvement?  Pointing out to the ISO mandate that an organization must commit to continual improvement in order to achieve and retain certification is not likely to help. Trotting out the Plan/Do/Check/Act graphic probably won't settle the concerns either, especially if you believe like I do that the phrase Plan/Do/Check/Act seems to be missing something. If the solutions were that obvious, I would have already planned it, done it, been checking it and acting smug. So what do you do?  In my case, I go for lunch at that font of ancient wisdom - the Chinese restaurant. And the advice that came to me in my fortune cookie was:

ISO 14001 does not explicitly oblige an organization to continually reduce its waste or continually improve some parameter. It does not require continual improvement of an organization's environmental performance. Rather, Clause 4.1 of ISO 14001 asks for the organization to improve its environmental management system. There is certainly a belief and evidence of support that implementation of an EMS will improve environmental performance, but the improvements are a product of the EMS. In essence, improvements happen when organizations achieve their environmental objectives and targets - the improvements are a product of the EMS and not an obligation of the standard.

How then does continual improvement happen?  Continual improvement is a result of the fundamental expectation in the standard that the EMS will not remain static; that once established, persons in the organization will uncover opportunities for additional efficiencies and new ways to accomplish requirements, and make adjustments to their EMS to improve its design, usage and/or outcome. It is adapting your EMS that enables continual improvement.

Continual improvement comes from the small and incremental adaptations that occur when procedures are streamlined or forms are simplified. Continual improvement results from adapting to changing concerns of the community and reflecting those changes in your significance analysis of aspects and impacts. Continual improvement results from adapting to the availability of internal personnel and consultants to adjust personnel mix for conducting internal audits. Continual improvement results from adapting your training to enable specialized feedback possible through computerized training systems - or providing more classroom style training because your aging workforce isn't as comfortable with computer-based training. Continual improvement results from adapting the scope of your EMS to include more operations as a result of senior management's desire to replicate the impressive results already delivered.

Every element of your EMS program is a candidate for adaptation and improvement - every process, procedure, document, work instruction, competence assurance program, form template and, record. When designed properly, your EMS can tell you what needs adaptation and improvement. Certainly, non-conformities identified through internal audits and certification or surveillance audits are opportunities for improvement. The entire corrective and preventive action process is designed to identify adaptation and improvement opportunities. The purpose of the management review is to address the question of whether or not the EMS as designed is currently appropriate for your particular organization with your specific activities, products, services, corresponding environmental aspects and current internal and external pressures. Said another way: what needs to be adapted in the face of current conditions?

A robust EMS will have an abundance of riches for adaptation and improvement as fresh ideas get aired and successes get passed along to other areas. An EMS that is struggling or even failing to achieve its goals and objectives has even greater opportunities for adaptation and improvement. While there is clearly a need to adapt in order to be able to achieve organizational goals, maybe the best answer requires reducing expectations, extending timelines or postponing projects. Adapting to the reality that not everything could be achieved at once, could enable the success you need - albeit in fewer areas. In this case, continual improvement is still possible; just not as quickly as originally planned or hoped.

So remember not just to eat the cookie, but to read your fortunes. You'll find yourself adapting to circumstances and continuing to make progress.

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.

To discuss this article or for more information about the ISO 14001 Guide, contact Curt at (281)341-8289 or email: cjohnson@stcenv.com