Fortune Cookie Wisdom: If We Do Not Change Our Direction, We Are Likely to End Up Where We Are Headed
Curt Johnson, CPEA, STC Senior Program Director, Richmond, TX
Every organization implementing a management system faces the question of why to do it. Why spend money on planning, training and documentation? You've got day-to-day systems; you've got routine procedures-why design an entire management system when you have work to do?
Many companies implement environmental and/or health and safety management systems when they are required to by regulation (e.g., process safety management programs for high hazard chemicals), or have little choice, due to supply chain requirements (e.g., threshold requirements for vendors) or the expectations of influential stakeholders (e.g., investors or unions). Others perceive advantages from regulatory initiatives (e.g., OSHA's Voluntary Protection Program) and enforcement concerns (e.g., Sentencing Commission Guidelines). An expanded discussion of these drivers can be found on our Resources page of our website - see Program Tools and Guidance).
But what if regulatory requirements, client/stakeholder expectations and agency incentives aren't enough? What would convince your management to devote resources to develop and implement a management system? After all, your capable EHS staff is already doing inspections, monitoring discharges, shipping wastes, responding to requests, conducting audits, submitting reports. Do you really need to make changes?
When I'm faced with difficult questions, I head to a Chinese restaurant for hot and sour soup and, just possibly, some inspiration. While pondering why someone would willingly set aside time and resources from completing day-to-day requirements to design a management system to ensure they're doing those day-to-day requirements, I received my bill, a fortune cookie, and the answer:
Why implement a management system? Instead of laying out a long list of reasons, answer this deceptively simple question: "Are you happy with where you are and where you're headed?" A few examples will likely jump to mind. Are you content that re-audits show a 30% recurrence of prior findings? Do you mind paying surcharges to the local POTW every month? Is your injury rate "just the cost of doing business"? Do you dread hearing that an agency inspector has arrived at the front gate? Does it bother you to meet a corporate training goal (and therefore receive your full bonus) only by paying overtime to train the last stragglers? Is it OK to delay the plant expansion until you can find every set of records requested by the permit reviewers? Is everything the way it ought to be?
If nothing bothers you, if you feel that everything is fine the way you're going-don't bother trying to change. Change, by definition, is doing things differently. Change is hard. Change can be disruptive. Change can help management revise areas that are inefficient, costly, or bothersome.
For each specific issue, the tendency is to attack it like a project: throw resources at it to figure out a better way. Although this approach solves specific problems, few issues in the workplace are isolated. Pulling on one strand stresses and strains the whole web. Improving management systems strengthens it.
Developing and implementing an effective management system calls for an initial and regular strategic review of risks, drivers, objectives, procedures and performance. Understand your needs and opportunities. Identify the most important issues and ensure you have the means, resources and controls to effectively manage those issues. The result? Your organization will run dramatically more efficiently. You'll spend less energy responding to surprises, with their interruptions and stresses. And you might have more time to enjoy hot and sour soup and ponder life's questions.
Curt Johnson, CPEA, is an STC Senior Program Director in Richmond, TX. He has more than 30 years experience in the development and implementation of environmental, health and safety management systems. Recent projects include developing the management system and its documentation for a major food producer; analyzing regulatory requirements for a large U.S. oil refiner and distributor; and assessing management systems conformance for an offshore fleet operation. Curt is the current author of
ISO 14001: Environmental Management Systems-A Complete Implementation Guide, published by Specialty Technical Publishers of Vancouver, B.C. To discuss this article or for more information about the ISO 14001 Guide, contact Curt at (281)341-8289 or cjohnson@stcenv.com. 
