The new Leadership clause has the potential to release a very savage cat amongst the pigeons. The implications and opportunities provided by this Clause have not yet been fully realised by many organisations or auditors.
All references to management system representatives such as environmental, health, safety and quality professionals have been removed.
‘Top Management’ are those who direct and control the organisation. They control budgets, allocate resources and delegate authority. Top management will include directors, chief executive officers, presidents, vice presidents, general managers, partners and superintendents. These people must now be the focus of audits – not environmental, health, safety and quality discipline specialists. Whilst there may be some resistance and some CEOs will not willingly subject themselves to audit and claim that they don’t have the time to get involved in the nitty-gritty, day to day operation of their management systems – if they want certification that’s exactly what they are going to have to do. This resistance would indicate that the existing systems are not naturally integral to the normal business processes.
Any management system must now be fully aligned with the purpose and strategic direction of the organisation. The processes, controls and tools must be fully embedded into routine and normal business operational processes – ‘bolt-ons’ are not allowed. The management systems must NOT be operating as independent systems in their own right with their own dedicated management structure and processes.
This is proving to be a most significant challenge for organisations with traditional old fashioned systems with closed thinking EHSQ professionals and auditors of the old school.
We are seeing misguided EHSQ professionals develop additional and very pointless bolt-on registers, forms and checklists that operational personnel must complete in order to meet the new Standards. No! This approach in itself invites a significant non-conformance. Any successful business is already fully aware of its objectives and targets, its operating environment and its interested parties. A successful top manager will already understand the business environment, any risks and opportunities – and how these impact on the organisation’s strategy. They will have already ensured that the system objectives are compatible with this strategy and have been aligned and cascaded across the company. A successful operating business will find that it is already meeting these requirements as part of its day to day management activities – we just have to confirm where this information is located and in what form it is held. This does not necessarily have to be documented.
Business operational leaders are now required to demonstrate that they fully engage in management system activities as opposed to only monitoring that these activities occur. The Clause includes a number of Leadership ‘doing’ words such as “taking accountability”, “promoting”, “communicating” and “engaging” which can be directly assessed and verified.
Internal and external auditors as well as ex-management representatives may be challenged by the above approach. These roles must be equipped to challenge top management, have a very good understanding of business management and the specific language or jargon used – they must be able to talk EBIT, profit and loss, resource management, the current economic pressures and a whole range of cross business topics. The old management representative will now have to become a business advisor in order to add any value and continue to comply with Annexure SL.
Remember – the involvement of the leadership team is not optional, it is mandatory. This is now about business management.