Corrective and Preventive Actions to Support Environmental Management
Do you think that corrective and preventive actions are a waste of time, or something that is only useful as a showcase for the registrar? I have found that many companies struggle with implementing effective corrective action systems, but here are some ideas on how you can use these tools more effectively in your company.
Using the Seven-Step Process in ISO 14001
I have written in Seven Steps for Corrective and Preventive Actions to support Continual Improvement about a good seven-step process that can be used to address the need for corrective and preventive actions in a company for ISO 9001. This blog is a must-read to understand the process of corrective and preventive action that I am showing here on this blog, because the same process can be applied equally well to corrective and preventive actions identified in the ISO 14001 Environmental Management System. Below, in order to better understand the applicability to ISO 14001, I will show you an example to identify how the process would apply to a problem identified in an EMS.
Before starting, make sure you understand the difference between “correction” and “corrective action” as explained in the above-mentioned ISO 9001 blog, because the best payback for your investment is to use corrective actions for bigger problems that are repetitive and recurring.
The Seven-Step Process in Action
Here is an example of how this process may be used for a problem found in the environmental management system. The process can be captured any way you wish, on paper or PDF forms, or even in a computer program – the important thing is finding the root cause of the identified problem and eliminating it to make sure the problem does not occur again.
Step 1) Problem definition. Using the “Should Be” and “Is” statements to make sure we have a good problem definition, our example will be:
Should Be: All chemicals in use in the organization must have a valid Material Safety Data Sheet (MSDS) with information for users.
Is: In the last three audits, new chemicals have been found in use without MSDS information available.
(In this case, it is good that we caught this in the audit process and didn’t have an accident with a chemical where the MSDS information wasn’t available for the first aid personnel.)
Step 2) Scope definition. In this case, the scope includes new chemicals (existing chemicals do not seem to have the same problem of missing MSDS sheets according to our data), and time does not seem to be a factor, as this has happened over several audits (likely months). Additionally, for this example, I am going to say that the investigation has found that the missing MSDS problem has happened in several different processes. This means that it is not just the chemicals being added on one specific company process that are problematic; it is systemic for all new chemicals purchased.
Step 3) Containment. Get MSDS information sheets for all the new chemicals that are missing them. Our containment is as simple as that. These sheets are to be supplied by the company that produces the chemicals, and should be available to be sent by the chemical supplier.
Step 4) Find the Root Cause. This is the trickiest part. I cannot go into a full root cause analysis, as this would become a very long blog, and as this is just an example it would likely be irrelevant. Below I have included a graphic of what a fishbone diagram template might look like for investigating a problem like this. In the fishbone, the problem statement is entered at the far right; then, all ideas of potential causes are listed under the different headings of the fish skeleton. By listing out all possible causes, you might get a good feeling on what the cause might be, or you can choose to test a couple of the most likely causes.
In our case, the cause is deemed to be due to the purchasing process (under Methods) not having a step to check if the chemical being purchased is new, and if so, if an MSDS sheet is available.
Step 5) Corrective Action Plan. The plan decided on for this corrective action example is to update the purchasing process to include this step for an MSDS check, and to get the information before the chemical is purchased.
Step 6) Implementation. To implement the plan in this example we have a few steps to follow: update the process or procedure, train all the purchasing people in the additional step (and update any training materials), and train all employees who may be asking for new chemical purchases that this is now going to be a requirement, so they can plan to have the information available early.
Step 7) Follow up to make sure the plan worked. The choice here is to continue to look for the problem of missing MSDS sheets in audits and see if the problem recurs. If the audits do not find the problem again in a decided amount of time, then the problem can be considered solved. If the audits continue to find the problem, return to the root cause analysis and try other potential causes.
And that is it.
Again, it is good to point out that this can not only be used on corrective actions (problems already occurring when they are found), but also on preventive actions (when the potential for a problem is identified even before it happens).
Corrective/Preventive Actions – the best way to save money
Again, it may seem redundant, but the biggest benefits can be realized by properly fixing the biggest problems. Wisely using corrective actions for the biggest problems is the most effective way to save money by driving continual improvement, and by doing so you will be able to really see the payback for the investment you make in implementing an ISO 14001 Environmental Management System.
Enroll in this free online training: ISO 14001 Foundations Course to learn more about nonconformities and corrective actions.