Chemical and Hazardous Substances Management

For Australian readers you would know that any hazardous chemical in your work place requires and MSDS and a chemical risk assessment.

Too many businesses I visit view chemical and haz subs management as an afterthought rather than an integral part of their purchasing process.

When developing your purchasing process, ensure that there is a section devoted to the purchasing of chemicals and other hazardous substances. You should work with the people using the chemicals to develop a list of standard substances and suppliers for purchase. Each supplier would need to provide current MSDS's and if possible a chemical risk assessment before any chemicals are supplied.

By determining set limits for purchasing stock you can ensure that you are not spending too much AND you have a better idea what quantities you are storing on site.

Far too many businesses have no idea what they have in their workshops/storage cupboards etc.

Document Control Part 2

Following on from my post yesterday about Document Control (sorry I ran out of time and didn't get to finish it).

My last tip was if you have to have a file path or location in your footer then you have a problem with your document control. 

To elaborate on that point, you need to set up a solid filing structure so that files are easily located. This includes the folder structure AND the naming protocol for your documents. 

You should try to stop employees having their own folders where everything just gets dumped and forgotten. Even if something is a work in progress it should be filed properly, marked as a draft in the file name and given a revision number.

I have a good example of a solid filing process but I'm not going to give away all of my secrets on here. If you have any questions about document control feel free to ask me in the comments section below.

Document Control Part 1

Aaaaaaah document control, everyone has to do it but no one seems to do it effectively. It always seems to be inadequate or total overkill.

If you follow the below guidelines you can't really go wrong and you can gain much greater control over your documents.

1. Before you even start writing your Document Control Procedure, pick someone within your organisation to take ownership of it completely. You want one person only to be allowed to create documents for approval. Others may create drafts but they must all be funnelled to this one person.

2. Choose somebody who is a bit of a stickler for detail. People who get annoyed if things aren't spaced properly or aren't aligned are great when it comes to keeping control of their documents.

3. Create a solid approval process. Your employees need to know that documents they create MUST be approved before they go anywhere. I have seen many tenders get messed up because it has been sent out without final approval and the price is incorrect.

4. Document control must be driven from the top. If you are the business manager or owner be on the lookout for document control issues and be sure to follow the process yourself.

5. Create a standard footer for all documents which shows the following details
- Page x of y (too many people just do page x, how do you know if a page is missing???)
- Revision Number or date or both
- Approved by (preferrably with a signature)

6. If you have to put a path in your document footer, it is a good sign that your document control system isn't working. 

I will continue this either later today or tomorrow as I have to do some real work but as always if you have any questions about document control please feel free to ask me in the comments below or shoot me an email

Aspects and Impacts

I apologise for the long delay between posts (not that there is a massive crowd awaiting my written word) but it means business has been good.

When building an Environmental Management System for the first time, The part that pretty much everyone gets wrong is their Aspects and Impacts (followed closely by legal and other requirements). The reason for this is fairly simple. Unless you have been trained in how to do it or have some assistance, it is actually very difficult and will require a lot of time and research to do it properly (depending on your business type).

When assessing your aspects and impacts you are essentially performing an environmental risk assessment on all tasks performed in your business. Unless you know what you are doing or have some guidance most people get it wrong because they don't know what they are doing.

If you are looking at getting your business ISO14001 certified do yourself a favour and enrol in a basic 2 day course on how to implement an EMS. It may cost you around $1500 but it is money well spent. Alternatively use that money to get a specialist to spend some time with you to explain how it works and how to apply it to your business.

If you have any questions though in regards to Aspects and Impacts contact me in the comments and I will be happy to help.

Surviving an Audit

Part of the fun of building a Management System of some description is knowing that at some stage you are going to be audited on it to get it certified.

Audits can be massively stressful for some people and I know myself I still sometimes get a few nerves when a client of mine is being audited for certification. The thought of getting a non-conformance and having to be re-audited makes me nauseous if a company has put a lot of time and money into it.

There are a few ways that you can reduce the pressure a little though.

If you have any areas that you know aren't quite up to scratch for gods sake do an in depth corrective action for them. Show that you know they are an issue and that you have a timeline for completing them. This can be the difference between getting a non-conformance or an area of concern. An area of concern or minor non-conformance is not a big deal and will be looked at in the next audit.

KNOW THE STANDARD. I know this is a bit of a no brainer but learn the standard inside and out and learn how to make it work for you. There is so much in a standard that is open to interpretation. Many auditors have their own idea of what needs to be done to fill a requirement but that doesn't mean you have to agree with them.

Don't be afraid to disagree with an auditor. If you think a decision on a requirement is incorrect then tell them. At the end of the day you are still their customer, you are paying them to do an assessment of your business.

Lastly if you have any people in the office that you think aren't going to be able to answer questions about the system properly, give them the day off or tell them to work from home or something. The last thing you need is some bright individual who hasn't paid attention to inductions etc to say something stupid. I've seen it before where a company has spent a lot of money trying to train their staff and some people just couldn't give two proverbials about it. It's embarassing having an auditor ask an employee about their environmental policy and they respond "what policy?"

Although stressful, the moment you realise that the audit is finished and all the auditor has to do is write their report is very satisfying. Every audit I have gone through feels like a little victory once it's over.

if you have any questions about the auditing process please don't hesitate to contact me

Writing Effective Procedures

One of the most important parts of developing any system is writing procedures that are easy to read by all levels of staff and will actually be used. This is pretty much a no brainer but everybody seems to get it wrong.

First of all, ditch all of the information at the start that you don't need. If you need to put the "purpose" of the procedure then you need to look a little more closely at the people you have working for you. I have honestly seen a purchasing procedure with the first paragraph being "Purpose: The purpose of this procedure is to explain the purchasing process of the business" really Captain Obvious?

Things such as "scope", "preamble", "introduction", are just padding and are just more inclined to make an employee put it in the CBF basket. If a consultant writes a procedure for you that takes a whole page before even giving you any actual information is just padding out their time basically.

I've always found the best thing to have at the start of the procedure is a responsibilities matrix showing the tasks involved in the procedure and who is responsible for looking after them. This way an employee can quickly scan the matrix, see what they are responsible for and then go to that section to see what they need to do.

After that any definitions that you may need for common abbreviations unknown to new employees may be necessary but a full page of definitions is once again just padding.

Depending on the procedure it might not hurt to reference any relevant legislation or codes of practice that may apply to the task.

After all that it is a matter of going through the process step by step and documenting it in clear language and then auditing it to make sure it is correct.

Writing a procedure doesn't have to take 2 weeks and as long as you have someone who knows the task well  to speak to you don't have to be an expert in it either. I have written procedures on how to maintain hydraulic front lifters without the slightest training in hydraulic mechanics because I researched the codes of practice and asked lots of questions. 

If you would like any assistance writing procedures for your business please feel free to contact me adrian@8020mc.com.au

Integrated Management Systems & Tendering

A lot of my customers come to me in response to a tender which has a requirement to be either certified to an ISO standard or have some form of ISO system in place. For some companies this the kick up the bum that they have been waiting for to put a QHSE system in place.

In reality, unless you have at least 3 months until your tender is due, you will not be able to implement a system and get it audited in time. I have helped some people get their system certified faster but they basically just said "we want it, we want you full time for 2 months and we want to start yesterday" This is a very costly way of doing things but sometimes if it is the difference between getting the job and not getting it, it is worth it.

If you don't have the time or the funds there are still a couple of ways of showing in a tender document that you are at least in the process of implementing an ISO system.

a. Contact a consultant like myself to help you get started with the basics. When this happens I will generally write a letter on our letterhead stating that we have been engaged to assist with implementing whatever system it is, and that we expect certification in however many months.

b. Do the basics yourself. You can generally put together a QHSE policy, a simple manual with the more crucial procedures, some forms (ie. risk assessment and corrective action) and some form of plan together to help get the tender across the line. If successful you can then start budgeting to implement the system properly.

As much as people would like to ignore it, ISO systems are becoming fairly common requirements in most tender documents these days. When it comes to the crunch if you are competing against someone with the same price and same relationship, the person with the better systems is going to win.

If you would like any assistance with your next tender please feel free to contact me.