Policies

Overview

The traditional approach to management systems implementation and certification is to focus on demonstrating literal compliance to a given standard (eg ISO 9001, ISO 14001, ISO 45001, and ISO 50001).

Most management systems are focused on documented processes. These processes are not necessarily consistent with the way managers get results in practice, even in heavily procedure-based operations, less than 30% of all activities are covered by detailed written procedures.

An approach focused solely or mainly on documentation leads to a disconnection between the system documents and reality; or as we term it, confusing the map for the territory. Having perfect documentation does not necessarily mean getting optimal performance on the ground.

We understand that managers use a broad range of techniques, which go far beyond the implementation of documented policies, procedures and work instructions, to deliver the operational and business outcomes they are seeking (production output, cost control, development of partner relationships and the like).

The ERM CVS Approach recognises that managers employ an effective range of techniques, which will deliver the right operator behaviours which should, in turn, reliably deliver the right EHS outcomes within your operations. Our approach is designed to help businesses improve EHS performance, not simply to improve their documentation.

ERM CVS's assessment approach

ERM CVS tests these linkages through ‘bottom-up’ root cause analysis and “top-down” focused discussion with management.

The right EHS outcomes will be produced if mainstream operational managers apply the techniques they naturally use in the pursuit of their operational goals to address the EHS aspects of the activities for which they are responsible. By recognising suboptimal performance and behaviour and identifying the underlying reasons for it we assist the organisation to focus improvement action on the right activities.

During the course of our assessments, we test if managers are properly integrating EHS considerations into their activities in a way which will reliably avoid incidents, assure compliance with regulations and continuously reduce the organization’s negative impact on people and the planet.

All our assessments are led by in-depth observation of conditions at the site itself. Assessments start with a detailed site tour, where the ERMCVS team will establish – through direct observation – if the organization is producing the right outcomes on the ground. Typically, our experienced assessors encounter some level of noncompliance with regulations, examples of poor control of risks and examples of unnecessary resource usage or waste generation. Our assessors use sophisticated root cause analysis techniques to determine the management causes which have given rise to these suboptimal outcomes they have observed. The content of the ISO standards is integral to this ‘bottom-up’ analysis.

Opening Meeting

During the opening meeting the ERM CVS lead assessor will confirm the assessment scope and the programme for the assessment.

The Lead Assessor will also take time to ensure that management understands that they will be receiving feedback on the practical effectiveness of their established EHS programmes and the level of support operational and other personnel are providing to this aspect of the organisation’s activities.

Site Assessments

This is where we take our ‘field first’ approach and get into the operations to observe what activities are taking place and how they are undertaken.

During the course of the assessment, our experienced auditors focus on physical infrastructure, work practices and areas of special interest in terms of the EHS aspects of the operations. They seek - through direct observation - evidence of sound and unsound EHS management practices.

We encourage our clients to take photographs of concerns we identify during the site assessment for use in the closing meeting and subsequently for their own training purposes.

The walk-rounds will allow management on site and the assessment team to develop a shared understanding of:

• The practical EHS issues which may be of concern;
• The effectiveness of the organisations established programmes (the quality of the outcomes observed on the ground will be indicative of the effectiveness of the established management programmes); and
• The management behaviours which have given rise to observed, undesirable EHS outcomes.

Business Performance Review

ERM CVS will conduct a review of overall business circumstances and emerging conditions through discussions with senior management. Areas of focus include mainstream operational excellence, financial performance, planned developments, and relationships with partners and other stakeholders. An insight into these issues will provide the assessment team with an understanding of the business context and pressures within which management of EHS takes place; this is likely to be vital to understanding the strengths and weaknesses in management of EHS within the operations.

Document Review

ERM CVS does not undertake an off-site document review as a stand-alone exercise. We may request certain documentation for our assessors to have sight of prior to the assessment but in the main we incorporate document review into our on-site activity. The types of documents we are likely to review in detail when on site are records associated with communications internally and externally, monitoring data, risk assessments, MOC analysis, KPI data analysis, compliance results and analysis, permit to work documentation, internal audit, management review etc.

Management Interviews

The management interviews – mostly with mainstream operational managers – will provide the assessment team (and on-site management) with an insight into the most effective management techniques employed within the operations and the extent to which these techniques are employed to address relevant aspects of the operations.

The assessment team will typically interview senior management across a range of disciplines, production managers, environmental, health and safety experts, finance personnel, human resource and training managers, performance improvement managers, facilities engineering and maintenance personnel, procurement specialists and contract management.

The requirements of the relevant standard are used as an agenda for the management interviews, which will be populated with observations and information collected during the on-site assessment and business performance review.

Meeting with Senior Manager

Prior to the closing meeting, the ERM CVS Lead Assessor will meet with the top-most manager for the operations and present their findings of the assessment. The primary purpose of this meeting is to provide senior management with an opportunity to digest the assessment findings, in advance of the closing meeting. This will then enable senior management to take the lead at the end of the closing meeting to set an appropriate forward direction.

Closing Meeting

Our closing meetings are designed to provide the management team with a realistic insight into the overall effectiveness of the programmes they have established to address the EHS aspects of their operations, and to provide a sense of how weaknesses in them may impact the business.

We describe how we have spent our time on site and the observations that we have made during the assessment. Wherever possible we use a selection of photographs of issues observed during the site assessment for this part of the presentation. We will provide feedback on the extent to which mainstream management are driving environmental, health and safety aspects of the operations and specific weaknesses in the mechanisms employed by them in this regard.

Our goal: to ensure management understand how their behaviours and the mechanisms they have established are influencing operator behaviours and the practical effectiveness (or otherwise) of these in delivering control of EHS risks, compliance with regulations and ongoing reductions in EHS impacts.

Reporting

The assessment team will prepare a report setting down a summary of issues reviewed during the assessment and any weaknesses in EHS management which have been identified. The report will mirror the findings presented in the Closing Meeting. Our findings are set down in three parts:

• Identified management weakness which needs to be addressed: description of the ultimate cause or causes of issues which were observed. This statement will include an assessment of the extent to which the management system is being complied with.
• Relevant facts and consequences: the assessment team’s observations which are relevant to the finding (for example a regulatory non-compliance or an observed poor practice). Statements regarding the possible consequences of an observation will be included where appropriate.
• Clause of the standard: the relevant part of the standard to which the finding applies.

Pathway to Certification and Enhanced Performance

Certificates of conformance to ISO 14001, ISO 45001, ISO 50001 and ISO 9001, which are valid for a three-year period, will normally be issued after completion of a two or three stage assessment process (pre-assessment, First and Second stages). Following issuance of the certificate, the operations will be subject to annual or twice-yearly surveillance assessments. The stages of the process and the tasks performed in each are described below.

Pre-assessment

Pre-assessments are an optional ‘extra’, which many of our clients incorporate into their programs because of the considerable benefits they derive from them. Pre-assessments will provide management with:

• A clear understanding of the status of EHS management within the operations and a clear understanding of the extent to which management of these issues is integrated into the operations;
• A clear understanding of overall weaknesses in EHS management - and consequently the level of conformance to the ISO standard;
• Support to EHS personnel in their efforts to raise management awareness of the importance of effective management and mainstream management’s role in ensuring that these aspects of the operations are properly addressed; and
• An understanding of ERM CVS’ approach to management systems assessment. There is considerable flexibility in relation to both the duration of pre-assessments and the tasks performed, but pre-assessments would normally incorporate each of the steps described in earlier (opening meeting, site tour, business performance review, etc).

First Stage Assessments

First Stage Assessments are almost always performed on site and will incorporate each of the elements of the assessment process described in the preceding sections of this document. The purpose of the first stage, is to determine preparedness for the second stage.

Second Stage Assessments

Second Stage Assessments are performed on site. The assessment team will spend most of their time with managers, supervisors and operators assessing if the organization’s EHS management programs are producing the right outcomes on the ground. Where shortcomings are observed, the team will seek to understand the management weaknesses which have given rise to them. The elements of the second stage assessment are as follows:

• Opening Meeting and Review of Actions Taken to Address Weaknesses Identified in the First Stage Assessment: Agreement of agenda and review of actions taken in respect of weakness in EHS management which were identified during the First stage assessment.
• Extensive Site Tour and Completion of Multiple Root Cause Analysis Exercises: Further analysis along the lines described earlier in this document, focusing especially on areas of concern identified during the First stage assessment.

Certification

ERM CVS’ decisions on certification are based upon the lead assessors’ evaluation of the extent to which management is engaged in driving EHS performance and have established the practical means to deliver operator behaviours which produce the right EHS outcomes across the operations. More specifically:

• Are EHS risks controlled in a manner which prevents incidents from occurring?
• Is management delivering compliance with their EHS regulatory obligations?
• Is management delivering on-going and meaningful reductions in impact on the environment, the work force, and the surrounding community?

ERM CVS only certifies organizations which have the means to deliver these outcomes and are achieving them, thus ensuring that certification is regarded as a meaningful measure of the organization’s EHS management, both internally and externally.

If a positive certification recommendation is made, a certificate will be issued after:

• Site-based management have provided a report on actions addressing any minor weaknesses in EHS management which were identified during the course of the Second Stage assessment;
• This report has been reviewed and approved by the lead assessor(s); and
• A comprehensive independent review of the assessment process and outcomes has been completed.

Surveillance Assessments

In order to confirm that the certified operations continue to properly address the EHS issues associated with the operations (i.e. in a manner which is consistent with the requirements of the standard); ERM CVS will perform annual surveillance assessments.

The surveillance assessments - like the initial assessment - will focus on on-going control of risks, on-going compliance with regulations and critically, continuous and meaningful reductions in the overall EHS impacts arising from the operations.

During the surveillance assessment the team would focus on:

• Close-out of weaknesses in EHS management identified in the previous assessment
• Changes in programs, personnel, process and materials used on site since the last assessment;
• A review of performance data;
• Testing the effectiveness of the programs on site - through further management review of specific program elements and through completion of several root cause analysis exercises during the course of an extended site tour (see Section 2.3). A report is issued after each surveillance assessment.

Recertification

ERM CVS certificates are issued for a three-year period after which a reassessment of the operations will be performed, the extent of which will depend on the frequency of surveillance assessments.

Conclusion

Ensuring that companies obtain the very substantial benefits that can be realized through the implementation and maintenance of ISO 14001, ISO 45001, ISO 50001 and ISO 9001 will be a significant challenge for management at all levels in organizations over the coming years and beyond. Achieving this end will require the involvement and co-operation of management and staff throughout the organization. Critically, it will also depend on the profile, capabilities, approach and professionalism of the certifier chosen to work with the operations.

ERM CVS works with its clients in a manner which will ensure that ISO 14001, ISO 45001, ISO 50001 and ISO 9001 certification enables organisations to enhance their environmental/health and safety/energy management performance and gain maximum value from the certification process.

Changing the Scope of Certification

In response to a request for a change to the scope of a certification already granted, the Project Manager will undertake a review of the requested change and determine any audit activities necessary to decide whether or not the change may be granted. An extension to the scope of certification may necessitate further onsite auditing activity, which may be conducted in conjunction with a surveillance audit.

A description of ERM CVS’s behaviour- and performance-based audit and certification process is available here.

Granting or Refusing Certification

The decision as to whether or not to grant or renew a certificate is taken by a suitably qualified individual (the certification reviewer) who has not participated in the assessment process and has no commercial interest with the client site being certified. The certification reviewer will take into account relevant information when making the certification decision, including relevant audit reports, detail of corrective actions identified and taken in response to nonconformities raised during the audit process, and the recommendation of the audit team as to whether to grant/renew certification.

Following a positive decision to grant/renew certification, a draft certificate will be issued to the client and, once this is approved, the final certificate will be sent.

In the event that certification is not recommended (or in the event that the certification reviewer decides not to grant certification), the Project Manager will communicate this to the client along with the reasons and details of next steps (generally, a further assessment will be required in this situation).

The client may appeal against any certification decision; details of the appeals process are available on the ERM CVS website.

Suspension or Withdrawal of Certification

ERM CVS may suspend or withdraw a client’s certification in certain circumstances. Typically, the request for certificate suspension or withdrawal will result from:

• Breach of contract by the client, including the non-payment of fees;
• Persistent or serious failure by the client's certified management system to meet certification requirements, including requirements for the effectiveness of the management system;
• The certified client failing to allow surveillance or recertification audits to be conducted at the required frequencies; or
• Failure to implement effective corrective and preventive actions
• Failure to comply with ERM CVS’ Terms and Conditions of Business.
• The certified client voluntarily requesting a suspension.
• The certified client does not maintain an active legally enforceable contract with ERM CVS.

If a decision is made to withdraw or suspend a certificate due to failures to meet certification requirements then the Project Manager or the Partner in Charge will contact the client to inform them of this and state the reasons. Prior to withdrawing the certificate, the client will generally be allowed a period for rectification, during which time the certificate will be considered suspended. Under suspension, the client's management system certification is temporarily invalid. During the suspension period, the organisation must cease any promotion of its certification. The time allowed should reflect the seriousness of the failure, but typically should not exceed 6 months.

If it becomes necessary to withdraw the certificate, the client will be notified in writing including a request for immediate return of the certificate and immediate cessation of the use of the certification mark.

Changing the Scope of Certification

In response to a request for a change to the scope of a certification already granted, the Project Manager will undertake a review of the requested change and determine any audit activities necessary to decide whether or not the change may be granted. An extension to the scope of certification may necessitate further onsite auditing activity, which may be conducted in conjunction with a surveillance audit.

ERM CVS will provide the status of a client’s certificate on request to the Accreditation and System Manager. This will indicate whether a certificate issued by ERM CVS is current, suspended or has been withdrawn. Our process on granting, suspending, withdrawing or restoring a certification is available here.

If you are a client of ERM CVS and have a disagreement or dispute concerning your certification or verification statement, which you have not been able to resolve through your Client Account Manager or Partner in Charge, then you may appeal in writing to the Accreditation and System Manager.  

For more details see our dedicated page here.

ERM Certification and Verification Services (ERM CVS) is the ERM Group's global provider of independent certification, validation, verification, assurance and training services. We believe in the principle of openness, whilst respecting the strict confidentiality of information derived from our clients. 

We recognise that it is necessary for us to gain privileged access to information needed to carry out our assessments adequately, and that it is essential we keep confidential any proprietary information about our clients. 

Mechanisms have been established to safeguard the confidentiality of the information created or obtained during our certification, validation & verification, and training activities at all levels of our organisation, including our Management, external bodies or individual assessors or trainers acting on our behalf. 

The key principles which underpin our mechanisms for safeguarding confidential information are: 

• All personnel involved in our certification, validation & verification and training activities (including contractors or other external organisations or individuals acting on our behalf) shall keep confidential all information obtained or created during our assessments, training delivery or other activities. 
• All client information, except for information that is made publicly available by our clients, shall be considered confidential.
• When we intend to place client information in the public domain, we will inform the client in advance of our intentions.
• We will not disclose confidential information about a particular client or individual without the consent of the client or individual concerned. 
• Where we are required by law to release confidential information to a third party, unless regulated by law, we will notify the client or individual concerned in advance of the information provided.
• Information about a client from sources other than the client (such as regulators and complainants) will be treated as confidential in line with our policy on confidentiality. 
• We have in place arrangements, equipment and facilities to ensure that all client information (e.g., documents, data and records in electronic or hard copy form) remains secure and accessible only by authorised persons at all times. 
• Where we need to make confidential information available to other parties such as an accreditation body, we will inform affected clients of this action. 
• Where a Certification or Verification scheme requires us to publish certain information, we will publish information in accordance with the scheme owner’s requirements, which the customer accepts as a requirement of the scheme.

The policy can be downloaded here.

ERM Certification and Verification Services (ERM CVS) is the independent ERM Group entity dedicated to conformity assessment, validation, verification, assurance and training services.  

To fulfil our purpose, we, ERM CVS, must inspire confidence and trust to stakeholders that we operate considering impartiality, confidentiality and risks, acting with professional care, competence and responsibility, being open and responsive to demands, enhancing our reputation. 

Being impartial, and been perceived as impartial by relevant stakeholders, is a fundamental element that governs our decisions, actions and beliefs, supporting us to operate with independence, neutrality, fairness, free of conflicts of interests, bias or pre-judgment.   

Commitment to Impartiality    

ERM CVS Senior Leadership is committed to: 

• leading by example, taking positive actions to improve our reputation, embedding the importance of impartiality in our culture, beliefs, decisions and actions.
• understanding threats related to impartiality, including self-interest, self-review, familiarity, and intimidation risks. 
• systematically reviewing our impartiality risks, considering our business context, relationships and activities, managing potential conflicts, to continuously improve our internal controls.
• assessing our practices, increasing our interactions and facilitating external oversight review of our impartiality processes.
• educating our teams to understand the concept and importance of impartiality. 
• engaging and empowering our teams to execute projects, contracts and engagements with impartiality and objectivity, not allowing commercial, financial or other type of pressures that can compromise our decisions. We empower our team to stop, when our impartiality is jeopardized.
• welcoming suggestions and concerns raised from relevant stakeholders related to impartiality. We investigate and we take actions proportionally to the magnitude of the risks identified. 

ERM CVS & ERM Relationship Management  

ERM CVS Global Managing Director/Managing Partner is ultimately responsible for ensuring that ERM CVS relationship with ERM Group promotes our independence, reputation, governance and impartiality. This responsibility includes:  

• ensuring ERM CVS is aligned with ERM culture, beliefs and behaviours, fostering positive collaboration and communication where appropriate, and maintaining adequate level of independence where necessary, to protect our reputation.  
• ensuring that ERM CVS is financially stable, balancing the provision of value to shareholders and investing in our business to increase our impact, to improve our portfolio and to expand our team and competence. 
• explaining the rules and benefits to secure ERM CVS impartiality and independence position.
• managing potential conflicts of interest, ringfencing impartiality threats, and reducing risks to acceptable levels.
• ensuring ERM CVS Partners and Directors are not responsible to lead ERM operational business units, projects, contracts and engagements, and vice-versa.
• ensuring ERM CVS team retains full ownership and independence to contract, to execute and to take decisions related to its projects and engagements.

ERM CVS’s impartiality policy can be downloaded here.

Certification and verification from ERM CVS is regarded as an outstanding mark of excellence in EHS management. 
 
We have established detailed requirements and guidance for the use of our certification marks and any associated accreditation marks that are provided to our management systems-certified clients. This information is provided to our certified clients and is available here. 
 
Verification and Validation statements must be used in their entirety, and the ERM CVS logo and/or accreditation marks are not available for promotion of these statements.