Systems vs. Controls

| October 14, 2012

Earlier this month, I attended the ISO Working Group meeting for the revision of ISO 14001 (TC 207/SC1/WG5).  This revision will result in a number of significant changes to the ISO 14001 standard.  These changes are likely to be carried over to a subsequent revision of OHSAS 18001.

There was a great deal of discussion at this meeting about a change that will fundamentally change the nature of the ISO 14001 requirements.  If this change is made, it will entirely transform what the ISO 14001 standard is all about.

The primary focus of the current ISO 14001 standard is on ensuring that an organization being certified has procedures in place to achieve the desired results.  The language of the new revision will change the focus of the certification process to verification of results (i.e. performance). 

For example, instead of requiring that the organization establish procedures to ensure persons working for it are aware of the EMS requirements (as set out in ISO 14001:2004), the proposed language (as set out in Annex SL) would change this procedural requirement to the following outcome requirement – “persons doing work under the organization’s control shall be aware of the EMS requirements.” 

Important note – For ISO management system standards,  a procedure is defined as “a specified way of doing something.”  It is NOT a piece of paper with the word “procedure” at the top.  Although many organizations decide to write down their procedures, creating a document is not necessarily required.  It is the use of a consistent process, not the piece of paper that is important.

There is a major problem with this change in focus.  

Activities where the outcomes of processes are dependent on human behavior are, by definition, a “complex system.” Complex systems cannot be understood by simply breaking them apart and modeling the various pieces. The interactions between the processes are as important as the inputs, outputs and controls of the individual processes that make up the system.

More importantly, we cannot predict the outcomes of complex systems with 100% accuracy. This is why weather forecasts are stated in terms of probabilities.

Systems theory also tells us that complex systems cannot be controlled – they can only be managed.  

We can seek to achieve certain results; we cannot guarantee certain results will be achieved.

This is why organizations establish management systems NOT control systems.  This is also why the focus of certification needs to be on whether consistent processes (i.e. procedures) have been established – NOT on what the outcomes of individual processes are at one particular point in time.

Once an organization has established procedures, the outcomes of the covered processes must be monitored on an on-going basis.  Based on this evaluation, the organization can make adjustments and undertake corrective action to ensure that the desired outcomes will continue to be achieved over time.  Complex systems do require continual attention.

For purposes of certification, it is the future performance of a management system that is most important; not the current outputs.  We want to know whether we can count on what the results will to be tomorrow, not simply that the results were OK yesterday.

Whether it rained yesterday is interesting; whether it will rain tomorrow is what we really care about.  That is why we watch weather forecasts. 

It is also why procedures are a necessary component of a management system.

© ENLAR Compliance Services, Inc. (2012)

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Category: OHSAS 18001:2007 Revisions, OHSMS Implementation, Standards & Certification

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