ISO 9001, ISO 14001, OHSAS 18001

for scrap recyclers

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1/4/09: Where do we need work instructions?

In setting up our ISO system, do we need work instructions for truck driving? Big difference of opinion around here. Please settle for us!

Work instructions are recommended for tasks that tend not to be completed correctly unless work instructions are used. I have never seen truck driving as a topic of a work instruction; this type of activity is adequately covered by intensive (and mandatory) safety training and other measures. Even if you went to the trouble and expense of preparing work instructions, I doubt they would ever be used.

12/14/08: Safety: OSHA's top 10 violations for 2008

What are the most common safety violations encountered in OSHA inspections?

A fairly typical list is available here. Not all of these are directly relevant to the scrap recycling industry. But some are very, very familiar.

11/21/08: Still a dangerous business

Sometimes it seems like the same accidents, injuries, etc. happen over and over. And occasionally a single scrap recycler endures two tragic events in just the matter of weeks. The article below, published last week, is a reminder to everyone in the industry to renew and live by the pledge "safely, or not at all."

ARKOMA, Okla. - A massive fire broke out at the Yaffe metal scrap yard Wednesday, just weeks after an explosion fatally injured a worker there.

According to Arkoma police chief Thomas Lenard, a shredder flew a piece of hot metal into a scrap pile, starting the fire.

This is the second major incident at Yaffe just this month. On November 3rd, residents within a quarter mile radius of the metal scrap yard had to be evacuated after an old artillery shell, that had supposedly been defused, exploded there, critically wounding one of the workers, 25-year-old Steve Fontenot. Fontenot died Tuesday in a Fort Smith hospital. Fontenot was using a blow torch on a demilitarized artillery shell when it exploded. . . .

11/2/08: When should we train internal auditors?

Our certification audit is 3 months away (ISO 9001). We have not yet started doing internal audits. When should we train our auditors and get the audits done? Should the whole system be audited before certification? Thanks for help. . .K. L., California

The whole system needs to be audited before certification. In fact, you may want to re-audit parts of the system if the initial audits do not come out well. Training of auditors should be done immediately before auditing starts. And I'd get cracking on it if I were you. Three months is not much time to complete this essential step. Good luck.

10/14/08: Shouldn't we just ignore consumer specifications?

Our consultant says that ISO requires us to prepare material to consumer specifications. #1, some consumers don't give us specifications at all. #2, according to our marketing people, the specifications don't really matter because the consumer inspects the material and pays us for what they decide it is. So our marketing people say we don't need to pay attention to specifications at all. Do you agree?

Uh, no. This question goes to the heart of the ISO 9001 quality standard. A key principle is consumer satisfaction and meeting consumer requirements. If consumers give us specifications (even verbally), we are required to aim our system at meeting those specifications. If they don't give us written specifications (which I acknowledge does happen), the correct course of action is to document, at our end, our understanding of the consumer requirements (usually as part of the contract). As an alternative, you could agree with the consumer to refer to a generic standard such as the ISRI Scrap Circular. (By the way, tell your marketing people I said, "Nice try.")

9/22/08: "Pre-signed" maintenance forms

During an audit, it was found that daily forklift inspection sheets were being filled out and signed in advance. The audit took place on Tuesday and the auditor found signed inspection forms for Wednesday, Thursday, and Friday. Because the checklists include some safety items, the nonferrous manager wants the safety manager to re-train operators on how to fill out the forms correctly. I think the nonferrous manager and team leaders should be responsible. What do you think?

Completion of paperwork is not the issue. The issue is: were the inspections actually done? I wonder if anyone ever asked that question. The purpose of the exercise is not to create paperwork; it's to assure that necessary maintenance and safety checks are actually carried out. I therefore agree with you that line management (nonferrous manager, team leaders, etc.) should be held accountable for making sure that this is done correctly -- the safety director, after all, usually has no management authority over line personnel (but yet is erroneously held responsible in cases like this). I would suggest also that the issue be examined elsewhere in the company. If this is happening in nonferrous, it's probably happening other places too.

9/1/08: Consumer specs in desk?

We control consumer specifications in an electronic file available to all traders. Some traders, however, keep various specifications in their desks for ready reference. Legal or no? --K.J., Virginia

Not legal. Traders should utilize only the controlled specifications. This is, however, very difficult to enforce. If traders can show that they utilize only the electronic (controlled) specifications when writing up contracts, etc., they would probably get away with it during an ISO audit. But I'd discourage this practice if I were you.

8/7/08: "ISO is too expensive": True / False?

Our company is working on setting up an ISO 9001 system. I think it's a good idea because it's forcing us to be more organized about how we do things. One of the owners keeps saying that "ISO is all right if you're making money. But otherwise it's too expensive." He claims that other companies who have ISO have told him this. Is it true? –B. H., Torrance, Calif.

Any ISO system is dreadfully expensive (and a complete waste of time and resources) if it is not correctly set up and/or implemented. In my personal observation, companies with systems that are well designed and conscientiously operated find that their ISO systems actually pay for themselves on an ongoing basis–through improved internal efficiencies, reductions in poor-quality costs (rejections/downgrades), etc.

Clearly, your boss gets his information from people who either have no direct experience with ISO 9001 systems, or (due to consumer pressure) did slap-dash implementations of paperwork-heavy systems that squeak through audits but return few if any of the benefits that good systems generate. Unfortunately, such folks take comfort in their pre-conceived notions and are unwilling to risk being confused by the facts. With that attitude at the top, your ISO effort is almost certain to fail. Good luck and I wish you well.

7/21/08: Job descriptions: yea or nay?

Aren't we required to have job descriptions in our ISO system? I get conflicting answers. Thanks -- E. H., Barryton, Georgia

In my experience the typical job description is excessively wordy, goes out of date quickly, and is generally not very useful. With an ISO system (9001, 14001, OHSAS 18001) having job descriptions are usually, in fact, redundant.

The Standards require you to define the qualifications and skills that an employee must have to be competent in a particular job function, and then prove that people in those job functions are competent in the skills.

With our approach to ISO implementation, we create, for each job function (not person), a "training plan." This is a table on a single sheet of paper that lists the qualifications and skills necessary to be competent in the function. People who come into the job already competent are signed off (certified) with no further training necessary. People who have gaps in their skills receive training in the skills listed on the training plan. All this is documented via signoffs on the training plans. (Backup records, such as sign-in sheets, course graduation certificates, etc., are kept with the training plan in the employee's training [not personnel] file.)

Besides qualifications / skills / training, the typical job description also outlines duties, responsibilities, and, in many cases, actual instructions on how to do jobs. This is where job descriptions get to be very wordy, windy, and, in time, obsolete. With an ISO system, such instructional material is documented in the process instructions (procedures and work instructions). These are maintained, kept up to date, and audited regularly.

Therefore, job descriptions as commonly implemented are not necessary with a lean ISO management system, and I recommend against using them.

6/30/08: Anti-theft rules: part of ISO?

Like many scrap recyclers around the country, we've been impacted by some new laws designed to curb scrap theft. Many of the new rules we were following anyway. We've changed our system as required to comply with the law, including pictures, thumbprints, etc. My question is this. Do we have to include these new rules in our ISO system? Right now we have a procedure for purchasing scrap, but it's pretty simple and straightforward. I'd rather not complicate our ISO procedure with all this new stuff. What do you think?

The ISO 9001 requirements for purchasing are fairly straightforward. They do say, however (brace yourself for a fair use quote): "The organization shall ensure that purchased product conforms to specified purchase requirements." Since a "specified purchase requirement" is that the scrap we're buying not be stolen, then it's logical to include these rules not only in our process (which we have to do to obey the law), but also in whatever document we have written for our ISO system.

The advantage of doing this is that, with the rules included in the ISO system, you'll then be routinely auditing yourself on compliance to those rules. Which is a good idea, considering the level of scrutiny that scrap recyclers are under these days.

6/11/08: Signage: How much? What kind?

I understand that material in our yard must be identified by grade. But a customer auditor was telling us that we also have to identify it by its 'inspection status'. What does that mean?

'Inspection status' means different things in different industries. In scrap recycling, generally speaking, the easiest way to define it is 'prepared' material (i.e. processed, inspected, and ready to ship, and 'unprepared' material (i.e. material that must be processed before it can be shipped).

That's the cleanest way to do it. I understand that material you've classified as 'unprepared' may in fact be sold and shipped that way. That's fine. It magically becomes 'prepared' as soon as you sell it to someone whose specification fits. But otherwise, if you generally expect that the material will need to undergo some kind of process -- sorting, shearing, baling, etc. -- you should classify it as 'unprepared' and the identification system you use (whether it is signage, diagram, etc.) should so indicate.

This is necessary to meet the requirement of ISO 9001:2000 7.5.3.

5/19/08: Auditors, not regulators

Auditors need to act like auditors. Not like regulators.

One of my clients is a multi-site manufacturer working toward certification to the ISO ‘trifecta' (ISO 9001, ISO 14001, OHSAS 18001). They are implementing a single integrated system to manage quality, environmental, and safety management.

Cooperation at their sites has been pretty good. But at one production site, line management has been, shall we say, extra touchy, extra defensive, at every phase of the process.

Some of this is understandable, and to be expected. We deal with it all the time. And I like to think we're pretty good at defusing these types of concerns. But here, the defensiveness seemed intractable.

Time came for the first internal audit. We went through the audit regimen, then informed site management that we wanted to sit down and brief them on our findings. The site manager seemed surprised that we'd review audit results with him before submitting our report with senior management. He said they were not accustomed to that.

At first I was puzzled. Why would we not brief site management directly? That's standard audit practice, as far as I'm concerned.

That's when we learned about their environmental consultant. He audits the production facility twice per year. However, he never briefs site management on his conclusions. Instead he turns in his report – which is mainly a recitation of problems – directly to the CEO at corporate headquarters.

This explains the site management's overall negative attitude. To them, these programs and related monitoring have become a complete negative. Understandably so. I explained again that we don't work that way. The site manager then informed me that the environmental consultant had been, in a previous life, an EPA inspector. That turned on a light bulb in my head. This ‘consultant' still thinks of himself as a regulator.

Wrong approach, in my view.

Of course as auditors we are duty bound to audit strictly to the standards, audit thoroughly, and render honest reports. Just as regulators do. But as auditors we are there first and foremost to serve the client. These requires us to go beyond what mere regulators do. It requires us to show client people – especially those at levels below top management – the utmost in common courtesy and respect; to treat the process not as a search for the guilty but as an even handed evaluation of the system, treating the auditees as participants rather than as targets.

That's why we review audit findings with line management before sending them up the line to top management. This approach in no way affects what we report to top management. But it gives the people in the trenches the chance to hear the news first, to make quick fixes where possible, and to be fully prepared for top management's reaction – instead of being blindsided.

Which makes us auditors – not regulators.

4/28/08: How to control our scrap sources?

Hi. I work for a small scrap processor in the northeast. Last month I attended a community college overview on ISO 9001. One thing that jumped out at me was this. They said we have to control our raw material sources. In my business, of course, raw material comes from industrial accounts and retail purchases over the scale. How does ISO expect me to control them? Please help me understand. Thanks.

In most organizations, raw material is available from a variety of sources. Companies pick the best sources of supply based on price and quality. Scrap recycling firms, on the other hand, compete for sources of supply. Therefore, the types of 'controls' that you heard about are not appropriate. Scrap recyclers 'control' raw material sources with price and inspection, and this is comfortably consistent with the ISO 9001 requirements.

3/14/08: Are we doing corrective action correctly?

I'm MR at a small specialty scrap recycling firm. Over the past several weeks I've received a number of corrective action requests -- from different people -- that, it seems to me, pertain to the same problem. They all really go back to, we are not monitoring our transportation vendors well enough. Can I bundle all these CARs together into one, and assign it as if it were 1 CAR to someone to handle?

First of all, I applaud you for putting some real thought into the corrective action process. Sometimes people just look at trees instead of stepping back to take a look at the forest.

Absolutely: it is acceptable to bundle these types of CARs together and take care of them with a global process of identifying root cause, corrective action, preventive action, verification, and close-out. By doing it this way you're calling attention to the fact that you're dealing with a systemic problem rather than just a hiccup.

Nice job -- keep up the good work!

2/21/08: Is this company really ISO certified, or not?

An Indian company I want to do business with says they are ISO 9002 certified. How do I verify that? I tried www.iso.org and can't find how to verify that.

ISO 9002 has not existed since 2003. So that may be a red flag.

Quickest way is to ask them for their certificate. Registered companies are always willing to send that out (it's a bragging point). Then verify it with whoever their registrar is. Most registrars have web sites with listings of their registered clients.

Failing that, you can search for them at whosregistered.com. Results here are not always dependable. Some firms I know are registered are not listed there. But it's another avenue.

Short answer: Until they can prove they are registered, I would consider them not registered.

1/30/08: Shredder explosions: must we measure?

As one of our performance metrics, we've been counting explosions in the shredder. We set goals, collected the data, reviewed it at management meetings, and put measures into place to try to reduce the explosions. I must say we've been successful. We cut the incidence of explosions by 2/3. For the past year, the number has flatlined. We're frankly getting kind of tired of looking at this at every management meeting and think we should just drop this from our metrics. What do you think? -- B. M., New England

The Standards do not specify what you must measure. You're expected to pick critical and important issues in quality, environmental, and safety; establish data gathering and objectives, and then strive to hit the objectives and improve. There is nothing in the Standard that says that once you establish a particular metric, you must keep it forever. Especially when just starting out with metrics, many of our clients find that some things just end up not being all that important.

With that said: shredder explosions are a significant issue for scrap recyclers. It literally impacts all the dimensions of the management system: quality, environmental, and safety. Minimizing explosions seems like a really good idea. I don't doubt that there's a point below which the incidence of explosions cannot be driven. But if you quit measuring them, and quit paying attention to this in management meetings, I can pretty safely predict that the frequency of explosions will, like magic, increase. "What isn't measured, isn't managed."

1/10/08: Flooding: an environmental interaction?

Our yard is near a river. Recently the county advised us that a 100-year-level flood could reach our turnings bins, which, if it happened, would release pollutant fluids. We're responding by purchasing flood panels that can be put in place in case of a flood warning. Is this something that we should address in our ISO 14001 environmental management system? If so, how? -- B. J., Iowa

Yes, you must include this issue in your environmental management system. Flooding is a potential environmental interaction, and the impact of a flood could be a release of pollution. Therefore, you should include flooding as an interaction on your environmental assessment; list the relevant laws / regulations; define the controls (flood panels) in some kind of documented, auditable format (i.e. work instruction), train appropriate employees, and -- if at all practicable -- carry out occasional practice drills to be sure that the flood panel control system is effective.

12/20/07:Treating the symptom instead of the cause

How not to handle a slip-and-fall hazard

Recently, a scrap recycling client's ISO manager received a Corrective Action Request (CAR) reporting a slippery stairway on the shear.

The ISO manager referred the CAR to the team leader. His response to the car was this. "Root cause: Seram crane leaking hydraulic fluid, making stairs slippery. Immediate solution: power wash and dry the stairway to eliminate slip hazard. Long term solution: practice better housekeeping."

What's wrong with this picture? Well, it's pretty obvious. But, somewhat surprisingly, this type of thing comes up all the time.

The team leader's response is simply to clean up the mess and maintain the area better. Obviously these things are important. But shouldn't they also investigate and resolve the hydraulic fluid leak? Isn't the leak the ultimate root cause?

Unfortunately there is an attitude in many scrap recycling operations that fluid leaks are par for the course and simply to be expected and dealt with. Tons of kitty litter is spread around leaking machines in scrap recycling companies all over the country. Bad enough the waste and the mess -- but even worse is the potential safety hazard that these types of conditions create.

11/29/07: 16% during 2006

What internationial management standards continue to grow in acceptance by leaps and bounds?

ISO 9001 and ISO 14001, of course.

Worldwide certification to ISO 9001 (quality management) and ISO 14001 environmental management) increased in both cases during 2006 by 16%, according to a survey published by ISO.

These findings illustrate how thorouoghly ISO management system standards are integrated with the global economy.

Currently, some 125 North American scrap recyclers are certified to ISO 9001 and/or ISO 14001.

Personal note: I first got involved with ISO standards in 1988 (one year after ISO 9000 was first published). I began work in the scrap recycling industry in 1993. I distinctly remember hearing certain very knowledgeable scrap industry figures state that year, with utter certainty, that "ISO will cease to exist in 5 years."

Not quite.

--Rob Kantner

11/18/07: SPCC plan - training requirements

We're working on our ISO 14001 system. In reviewing our Spill Control (SPCC) plan, I find that it includes many training requirements and protocols that we are not, in fact, utilizing. We have a documented training program but it's much slimmer than the one in the SPCC book. What should we do?

A basic rule of ISO management systems is that you should not post the same instructions in two different places. I suggest you amend the training plans in the SPCC book to make them 'real world', and go from there. If you have questions about the necessary training, write to us again or confer with your environmental consultant.

11/1/07: Changes to ISO and OHSAS standards?

I've heard that ISO 9001 is changing again soon. Is this true? What's involved? Also OHSAS 18001, the safety standard - I've been told that a new version is out. What's the scoop? -- Mary McM., Brattleboro, VT

ISO 9001 is slated for revision but the latest word is that the revisions won't be implemented until 2009. I've seen the proposed revisions and they are very minor -- nothing like what happened in 2000. As for OHSAS 18001, a 2007 version was published earlier this year. The changes are not terribly serious; we'll have a directory of these available soon.

10/18/07: Car crushing and substances of concern

Our car crushing crews work at various auto salvage yards. We ask the yards to sign waivers promising to remove substances of concern, such as gasoline, freon, etc. from the vehicle before we crush them. But sometimes we get vehicles where this has not been done. Some of our people think we're 'covered' because the salvage yard signed the waiver. What do you think?

Tough issue. The responsibility for preventing pollution doesn't just go away because a piece of paper got signed. In my view, the owner of the car body is responsible for controlling the environmental impact arising from dismantling or crushing the vehicle. You may want to consider 'rejecting' vehicles where proper removal of substances of concern has not been done -- or get equipped to do the removal yourself, for a fee, of course.

10/4/07: Emergency drills?

What kinds of emergency drills should our scrap metal recycling facility conduct to comply with ISO and OHSAS requirements?

In most scrap recycling operations there are hazards and risks galore - environmental as well as safety. And in most scrap operations (not all, alas) there are procedures in place, backed with training, to deal with emergencies.

Trouble is, you don't know how well – or even if – the procedures will work until you try them out. It's a little late, many organizations have found, to try them out when an actual emergency arises – only to find out that the procedures don't work well.

That's why we recommend periodic practice drills to test key emergency procedures. This should be done on an unannounced basis. Set up a drill, run it, observe the results, and take action to remedy identified problems.

For scrap recycling operators, some key areas for practice drills include:

• Spill control. Tell people in a work area that a massive fluid spill has just started; see how long it takes for them to react effectively.
Fire protection. Fire drills are important especially in confined areas.
• Injury. How long does it take first responders to get to the scene? What's the availability of first aid equipment and supplies?
• Flood control. One of our clients has specially made flood panels that they'll put in place to protect a turnings bin in case an adjacent river flash-floods.
• Radiation monitor. Especially the gate monitor at the scale. Do scale operators know what the safe practices are if they get a positive reading?

Some client people say, "We don't have time for this." We think you should make the time. This type of preventive action can spare you a great deal of inconvenience, expense, legal trouble – and even heartache – later. --Rob Kantner

9/6/07: Final inspection of scrap

I heard you say at an ISRI talk that scrap metal recyclers should be able to get rid of final inspection of material before shipment. I can't believe you really meant that. If we don't walk the cars or the trucks, or check inside the tops of gaylords or whatever, how will we know the material is good? Thanks -- J.M., Fargo, ND

What I have said is, earlier material inspections (i.e. at receiving, sorting, production, etc.) should be rigorous enough to eliminate the need for 'final' inspection of prepared material as it is being loaded out. If 'final' inspection of material is necessary, it means that earlier production and inspection processes are inefficient and should be investigated. --Rob Kantner

Download Rob Kantner's Recycling Today article

Here's a free .pdf of Rob Kantner's article "Measuring Up," which appeared in the April 2007 issue of Recycling Today. The article compares and contrasts the various certification standards available to scrap recyclers, including ISO 9001, ISO 14001, OHSAS 18001, RIOS, and ANSI Z-10.

Marketing/sales and ISO 9001

Via email: tell me about the marketing & sales in ISO 9001.

Rob Kantner answers: Marketing and sales are engaged in the quality management system via three processes:

• Customer communication
• Determination of requirements (in which requirements of customers, as well as legal / regulatory requirements pertianing to the order, are established);
• Contract review (in which the actual agreement between supplier and customer is reviewed for adequacy and capability before acceptance).

The second and third items above are critical processes because if they are not carried out correctly, the rest of the process for satisfying the customer may be flawed. And even if such errors are caught later, that can come at significant costs -- both internal, and in terms of customer satisfaction.

New EPA spill control rules announced

The new rules ease up on some of the requirements. Read the press release here.

Corrective action: where should we do it?

Via email: I have a question about corrective action. We're implementing quality, environmental, and safety in our scrap yard and there's a lot of argument over where we have to do corrective action. I don't want this to become overwhelming! Help!

As a general rule you must carry out corrective action on:

• Consumer complaints
• Material rejections and/or downgrades
• Internal audit noncompliances
• Adverse environmental events (i.e. significant spills, releases, events that cause pollution to land, air, water)
• Accidents / injuries

Beyond this you must also carry out corrective action on system process problems irrespective of quality / environmental / safety. We encourage clients not to impose limits on what can be brought up as a potential corrective action. You can have a screening process to weed out the trivial problems. Otherwise, encourage all employees to document quality, environmental, and/or safety problems in a Corrective Action Report (CAR). It's a way of keeping everyone engaged in the system and creating opportunities for improvement.

Real world benefits of an OHSAS 18001 system

Via email: What improvements, in your own personal experience, are you seeing with companies who go on to OHSAS 18001?

Improvements I have seen include --

• With an 18001 system, responsibility for safety awareness and management tends to be spread out, whereas without it, in many firms, there is a single "safety" person who is looked to for everything. (Consequence of that can be that if that single safety person leaves or whatever, the program nose-dives.)
• Most safety programs emphasize regulatory compliance and more or less are content with that. An 18001 system involves programs for actually improving safety performance and I have clients whose safety performance has actually improved as a result. Though this is a requirement of the specification, I admit that not every company I've worked with is aggressively working that aspect of it.
• Many -- not all -- existing safety programs include some form of internal monitoring. Where this exists, it is often hit-or-miss. With an 18001 system, safety processes and controls are subject to ongoing internal audit (just like the quality and environmental management processes), which -- no question -- improves awareness and results.
• For some clients, the credential is meaningful from a p/r standpoint. This may become more important as time goes by, specially if and when ISO gets around to deploying 18001 as an international standard.

Local laws and ISO 14001

Via phone: Help! Our scrap yard got certified to ISO 14001 five months ago. Just this month our city passed a new ordinance that affects certain nonferrous materials that we purchase over the scale. Besides getting ID from the sellers (which we've always had to do), we now have to hold the material for 15 days, and permit public inspection of it, before we sell it. Obviously we'll obey the law (our local constabulary sent us a letter about enforcement) -- but does this impact our ISO 14001 system in any way? I suspect it does but our owner says it doesn't. Please help.

ISO 14001 requires you to list and have access to laws / regulations that you are subject to. So that local ordinance would need to be added to the list. You'll also need to prove that you check your own compliance to that law as well as the others. Should be a relatively easy matter to add this to your current laws/regulations process. Good luck! (If you were also ISO 9001 certified, there would be additional measures you'd need to take.)

How to organize MSDS?

Via email: Do you have any "lessons learned" on how best to organize Material Safety Data Sheets (MSDSs) at a scrap metal recycling facility. Our company is in the process of reviewing/updating our MSDSs, so we are looking to see what has worked well for others. Please let us know. -- Bruce J.

The "typical" scrap company has no organization method whatsoever for MSDS's. We often find them thrown into drawers or stuffed into binders with no particular organization applied. Of the examples I have seen, the optimal method is to organize them in a way that facilitates easy recovery / reference. So we've seen them alpha by substance. We've also seen them alpha by supplier first, and then by substance. Whatever is the most logical. Up from there I've occasionally seen them scanned into electronic systems, and/or indexed in databases for fast recovery. This is obviously optimal. Hope this helps.

Visitor safety?

Via phone: We're having an argument about safety rules. Is OHSAS about employee safety? Or does it require us to control the safety of others -- such as yard visitors? I've read the thing three times (nearly putting myself to sleep) and I don't see anything about visitor safety.

You must have skipped the 'scope' section. It clearly says that an 18001 system is intended "to eliminate or minimize risk to employees and other interested parties who may be exposed to OH&S risks associated with [your] activities." Clearly, visitors to your yard are exposed to safety risks. Therefore, your system must address the safety of nonemployees such as visitors and contractors.

Questions about specifications (with answers)

Question 1: In our procedure about specification control, should we refer to ISRI Scrap Circular and our notification to our customers to define our specs to be per the ISRI Scrap Circular, plus any additional items in the spec book?

Yes.

Question 2: Is it acceptable to use individual contracts / orders as the material specification rather than having specifications in a book?

Yes. When this occurs, the employees must know how to access the specs, which will be in the order. The method to access the spec should be to go to their leader, who can get the order.

Question 3: Do we have to put the ISRI Scrap Circular in the spec book?

Yes, or make reference to it and make it available -- in hard copy or by link to the online version.

9000 Solutions Group changes business name

Same business, same ownership, same staff, different name. 9000 Solutions Group is now Kantner & Company, Inc. And oh yes, same location, too. . .headquarters in central Michigan, operations all over North America. Next: China!

Lockout / tagout work instruction?

Via email: Can you show me what a lockout / tagout procedure for a shear might look like?

Sure. Download a sample here. (Note: download expires Friday midnight, 5/20/06.)

"Lead auditor" training: is it required? Or necessary?

Via phone: We just got certified to ISO 9001, ISO 14001, and OHSAS 18001. During the registration audit, the assessor told us we "should" put at least one of our staff people through the 5-day "Lead Auditor" training course. There's a different one for each of the three standards, and he said we "should" get Lead Auditor training for all three. Though he didn't come right out and say it's required, his "should" was pretty strong. This training is pretty expensive and takes 15 working days. What should we do?

Lead auditor training has always been the most oversold training in the ISO business. As you say, it takes a lot of time and it costs a lot of money. What you get for it is an intensified version of internal auditor training: more intense coverage of the Standards, more instruction in the audit steps (including role play in many cases), a very stressful final exam, and the longest of long weeks. Such courses were designed for, and continue to be intended for, training registration auditors. Not for ISO system end-users.

Are certified/registered companies required to have "lead auditor" training graduates on their staffs? The answer is a resounding NO. Does such training add value to any aspect of a certified company's ISO system? In my judgment, the answer is an equally resounding NO. Not for the time and cost required. If you have time and money for ongoing training, there are much more fruitful topics to obtain training in: root cause analysis, statistical tools, etc.

For those individuals with a) an especially avid interest in management system auditing, and b) time and money on their hands, and c) a potential interest in becoming a registration auditor someday, lead auditor training could be worthwhile, if you get the training from a reputable source. (We do not provide this training, but we can refer you to competent organizations that do.)

Can we calibrate our own scales?

Via email: We currently use an outside source to calibrate our scales once per year. Can we purchase our own calibrated weights and calibrate the scales ourselves? If not, can we get a member of our organization certified and if so how would we go about it?

Yes, you can absolutely calibrate your own scales as long as the weights you use to calibrate them are certified and come with traceability to NIST standards. You obviously need to define the calibration intervals, procedure, and the amount of allowable error, and keep detailed records.

Are ISO implementation and maintenance costs tax deductible?

This was news. At least, it was news to US. Check out the official IRS bulletin here.

Are "ISO cheat sheets" permissible?

Via email: In an ISO system, is it permissible for someone to have a "cheat sheet" at her desk? That is, it is a piece of a work instruction, but it has more detail (detail that is not needed in the work instruction) that makes it easier for her to follow (and someone else who may do her desk for a day). The info on this sheet does not disagree with the work instruction, mind you - it is just more specific.

If people get caught with these types of notes, it's a noncompliance. Not a major unless it's rampant, but it's contrary to the whole purpose of the system, which is that we control such job instructions. If the person doesn't find the work instruction sufficiently helpful, then he/she is obligated to propose changes to the work instruction, and if he/she is a subject matter expert, that's all to the good. PLEASE nip this in the bud wherever you find it.

/

Must lockout tagout instructions be posted on the machines themselves?

Via email: We just had an OHSAS 18001 safety management system audit and the auditor claimed that OSHA requires us to post lockout / tagout instructions and equipment on the machines themselves. I've never heard this before. Is it true? -- California

I can't find any such requirement. Obviously people have to be trained in the methods and be able to demonstrate competence. And instructions should be documented. But posting them on the machines themselves -- sounds like your auditor is practicing regulatory inflation or something.

/

"We meet or exceed customer requirements"

In an ISO 9001 system, you are required to develop, publish, and promote within your company a "quality policy statement." This is a brief statement of top management's commitment to quality and to customer satisfaction.

Just about every quality policy statement says something about the company's commitment to meet customer requirements. The problem is that many companies, without really thinking about it, say that they "meet or exceed" customer requirements.

It's the "or exceed" statement that can get you into trouble. Managements include it reflexively, without thinking about it. But you can be asked, at certification audit, to show exactly what you do to exceed/ customer requirements. And you can be asked to show examples of where you have actually done it.

So before you finalize and publish your policy statement, think through what it says. You're held to it.

The 10 traits of an effective internal audit team

We've been developing internal audit programs, and training internal auditors, for over a decade now. Often we're asked to describe the profile of an ideal internal audit team. Auditors should:

• Be bright, alert, engaged.
• Be able to read and write, with above average communication skills.
• Enjoy interacting with others, while maintaining independence.
• NOT be driven by an overwhelming need to be popular with everyone.
• Be consistently ble to maintain an objective, nonconfrontational, improvement-driven attitude.
• Have some level of analytical ability.
• Demonstrate commitment to the organization -- i.e. not just here for the paycheck.
• Be considered as having a strong future with the organization. (Auditing is an excellent professional development activity.)
• Represent a diverse range of organization operations, processes, activities (i.e. some marketing, some accounting, some production, etc.).
• Most likely be mostly salaried / supervision / management people, though if there are hourly / production people who otherwise fit the above profile, it's excellent and highly desirable to have them on the team also.

Rob Kantner addresses WISRI on scrap recycling environmental management

Having just been selected to develop the generic scrap recycling Environmental Management System (EMS) for Wisconsin scrap recyclers (in conjunction with the Wisconsin DNR's Green Tier program), Rob Kantner spoke to the February chapter meeting of Wisconsin Institute of Scrap Recycling Industries (WISRI) in Madison. Read the full text of his address here. Excerpt: "An effective EMS puts you on a par with industry leaders worldwide. It’s a heck of a credential. . . . An effective EMS sets a positive example: for suppliers, customers, consumers, competitors, and the community at large. It’s good corporate citizenship, which is the same thing as good public relations. And every recycler knows how important it is, in our industry, to maintain good public relations."

ANSI Z-10: how does it compare with OHSAS 18001?

Via phone: You guys help scrap recyclers implement OHSAS 18001 systems for safety management. I'm hearing a lot about ANSI Z-10. What's the difference?

ANSI Z-10 (more formally, ANSI/AIHA Z-10 2005) is a relatively new American national standard for safety management. Like OHSAS 18001, it follows the same PDCA (plan / do / check / act) model of ISO 9001 and ISO 14001. But there are significant differences between Z-10 and 18001. Generally speaking, Z-10 is more detailed and more prescriptive. For instance:

• The responsibilities of top management are strongly defined. In particular, Z-10 more strongly expresses the responsibility of top management for providing all forms of resources necessary for effective imp and operation.
• Like 18001, Z-10 requires hazard/risk analysis. But it openly recognizes change and the necessity for managing change, by requiring ongoing reviews.
• Z-10 obviously requires that controls be put in place to manage identified risks and hazards. But Z-10 prescribes a hierarchy of responses to identified hazards/risks, ranging in order of priority from elimination to personal protective equipment.
• Z-10 is very specific in its requirements for identification and control of associated hazards and risks pertaining to contractors and visitors, Training of contractors is mentioned.
• Unlike 18001, Z-10 pretty much mandates testing of emergency responses (i.e. drills)
• The training requirement is more specific and prescriptive. Trainer competence must be verified, and training must be provided "in languages trainees can understand."
• Management review is called for and the requirement is (as with ISO 9001) much more detailed and prescriptive.

Another free download! Aluminum dross work instruction

Aluminum dross is a serious environmental and health/safety concern for scrap recyclers. Our exclusive Scrap/QES management system helps scrap recyclers like you control and manage such aspects of your business. Check out our Scrap/QES work instruction for aluminum dross management. This free download is available only til Friday, January 27, 2006.

Check out our free Contractor safety policy here!

Safety management standards, including OHSAS 18001, require you to control safety processes for contractors who visit your site. Our exclusive Scrap/QES quality / environmental / management system includes a Contractor EHS policy. Download your free version of it now. (Note: this free download expires Friday, January 5.)

Do it yourself ISO system for scrap recyclers here now!

Scrap/QES -- the recycling industry's only do it yourself integrated quality / environmental / safety management system - is here now.

Metal identification work instruction?

Via email: We use several different methods to identify various metals in our metal room. For our ISO system, should we write some kind of instructions for these?

Yes. But you don't need to reinvent the wheel. Just modify the generic one we created for our upcoming Scrap/QES management system.

ISO 14001 environmental management. . .simplified

In response to several client requests, we've created an easy to understand flow chart of ISO 14001 (environmental) management processes. Download it free right here.

When? When? When? When?

When will they ever learn. . . that when you put flame up against steel containers, bad things happen. . .again , and again, and again.

Management of mercury switches: a Scrap/QES work instruction

Regulations are getting tougher on management of mercury switches and capsules in a scrap yard. Recyclers who implement our upcoming Scrap/QES system will be provided with a work instruction for managing these hazardous items. Take a sneak peak at the work instruction here. This free download is available only through Wednesday, November 9.

Office safety in the scrap yard: a work instruction from Scrap/QES

When we talk safety in a scrap recycling company, we mostly talk about safety in the yard: from flying objects, falling items, hazards of all kinds. Most scrap recyclers never even consider their offices when doing safety risk/hazard analysis. Our upcoming Scrap/QES system (ISO specifically for scrap recyclers) includes office safety in its safety risk/hazard analysis. Take a look at the work instruction developed for Scrap/QES -- just one of over 20 safety related procedures, instructions, and schedules that are part of Scrap/QES. (Warning: this free download is available only until Friday, October 28. Then it vanishes!)

Three cheers for the Badger State!

Wisconsin Department of Natural Resources (DNR) and the Wisconsin Cooperative Compliance Program (CCP) -- a group of leading Wisconsin scrap recyclers -- have signed a Compact that will result in closer cooperation between state scrap recyclers and regulators to improve environmental performance and environmental results. Details here:
Feeding Good Habits: Wisconsin Recycling
Scrap Recycling and Green Tier
Green Tier Charter (Recycling Today)

Job descriptions for a scrap yard?

Via phone: We’re a medium-sized scrap yard in the northeast. Like many scrap recyclers, our employees wear lots of “hats.” So coming up with job descriptions for them is tough. Can you help?

Rob’s answer: There are several ways you can go with this. But the first thing you need to do is focus on _job functions_, not individual people. Make a list of all the separate job functions in your business. Then, for each, list the qualifications and skills that a person has to have to meet the job’s requirements. Generally, this is 4-10 single line items. Each function’s qualifications/skills list goes on a document that we usually call a Job Sheet.

Now identify each employee’s job function(s). As you say, many will have more than one. If, for example, Mary is a scale operator and inbound inspector, she’ll need to be qualified in each of those separate sets of skills. Her training file will include a scale operator job sheet and an inbound inspector sheet. Other employees will have just one sheet; some will have three or more.

With existing employees, you certify that they meet the job qualifications simply by signing off on their job sheet(s) that they are qualified, by virtue of their years of experience on the job. When you bring in new people, or transfer existing employees to new jobs, use the qualification sheet as a) a guide to training, and b) the record/signoff that the person has been trained and qualified in the job.

You’ll notice that, so far, I have not mentioned job descriptions. That’s because job descriptions per se are not necessary and, in fact, can be much more work than is worthwhile.

Mercury switches - and you

Following a trend that's occurring nationwide, the North Carolina legislature has passed a bill concerning scrap recyclers and mercury switches.

Managing PCBs and capacitors

When you buy scrap over the scale, you run the risk of dangerous items entering your process stream. PCB-bearing capacitors are one of the worst, and regulations are strict about them. Here's a free work instruction with steps for your people on identifying and handling capacitors. It's a free download, for one week only!

Know what you're torching (part 2)!

This time in Washington: torchers, gas tank, second- and third-degree burns. . . .

Know what you're torching!

An Indiana metal salvage worker pays a high price for not knowing what was inside the container he was torching.

Are your torchers sufficiently protected from health hazards?

As a result of a Health Hazard Evaluation, the National Institute of Occupational Safety and Health (NIOSH) found that workers burning scrap at Omnisource's Lima, Ohio facility were overexposed to lead, cadmium, nickel, copper, and inorganic arsenic. The story and list of recommended remedies is well worth reading.

Environmental best management practices: are you covered?

Your storm water permit/program (SWPPP) and spill control program (SPCC) include lists of "best management practices" that you as a scrap recycler have promised to implement. Besides the occasional external audits that you undergo -- which are sometimes cursory -- how do you know you are actually abiding by these BMPs? Can you prove that you are? In our work within the scrap recycling industry we're finding that this is sometimes an issue. We recommend, at the very least, that the BMPs be monitored internally via a specific checklist that covers all the action items. If you've got a problem, it's better to find out yourself -- and correct it -- before an outsider does!

For an example of such a checklist, call (989) 561-5005.

New licenses for scrap recyclers?

"Scrap scavengers" -- people who steal metal for sale to scrap recyclers -- are "getting out of hand" in at least one major American market, and the government there is proposing laws to monitor scrap recyclers. News article here.

Document control questions

Via email: I attended an ISO class where the instructor said that our procedures have to include a) list of forms used in the procedure, including revision level and revision dates; b) revision history including brief explanations of what was changed with each revision of the procedure. This sounds like a lot of bureaucracy, and when I asked where ISO 9001 requires us to do that, the instructor had no (real) answer. What's the scoop?

He/she had no answer because there is no such requirement in the Standard. Listing the forms is a good idea, but it's neither necessary nor convenient to list revision level and revision dates of the forms; that's found on the forms themselves. As for revision history, this is also unnecessary -- if you keep an archive of obsolete versions. That archive functions as an adequate revision history.

Surveillance audit

Used to be that the certification audit was the be-all and end-all. Not any more. I don't worry about clients passing that audit. By the time we're done with them, we know they are ready. What we /do/ worry about is the first surveillance audit, which usually happens 6 months later. Sometimes the system slides during those six months. . .and the client has unwelcome results from the audit.

So it's always happy news for us when a client does well in that first surveillance. Such is the case with Wilmington Iron & Metal, our first QES (quality / environmental / safety) registration. They just had their first surveillance and came through with flying colors. Hats off to Fred and the Wilmington team!

8 Great Fallacies about ISO 9000

Here they are, together at last: all 8 of the great fallacies about quality management. . . .along with "the straight scoop." Take a look now and further your education!

Your environmental controls may be dangerously people-dependent.

Rob Kantner discusses a problem with environmental controls commonly found in scrap recycling firms. Our first environmental management briefing here.

Why not self-certify to ISO 14001?

Via phone: A person from our state’s Department of Natural Resources said that we can be self certified to ISO 14001. I always thought (and your web site says) that I’d have to hire an outside company to certify us. Why should I do that if I can be self certified?

It is true that the ISO 14001 standard talks about options other than third party certification. For example, in the introduction, it says that the Standard "can be used for certification/registration and/or self-declaration of an organization's environmental management system." Section 1, paragraph c, states that ISO 14001 can be for an organization that wants to "demonstrate conformity with this International Standard by 1) making a self-determination and self-declaration." And a little further on the Standard mentions the option of an organization "seeking confirmation of its self-declaration."

Note that the term used is "self-declaration," not "self-certification." There is a big difference. In the context of management systems, certification (or "registration") means that a system has been assessed by an independent, impartial, and accredited / qualified third party organization, and found to comply fully with the requirements of the Standard. By this definition, no organization on the planet can certify itself. "Self-declaration" is simply a claim by the organization that its system complies with the Standard. Unlike certification, with self-declaration there is no independent assessment and no objective evidence. It’s simply an assertion, which may or may not be credible. With any of these Standards you can, in fact, go one of the following routes: a) third party certification b) second-party audits by whatever customer(s) care to do so; c) self-declaration with confirmation (by somebody else, attesting to the compliance of your system, or d) self-declaration without confirmation.

Of these, third party certification has the highest level of credibility, and that’s why many customers require their suppliers to be certified.

Problem scrap recycling process?

Via phone: From a quality management standpoint, which scrap recycling activity is toughest to get into compliance with the ISO standard?

What's often called "brokerage." More generally, the process of direct-shipping material from source to consumer, without intermediate processing or verification.

Will we be in trouble with our certification auditor?

Via email: In an internal audit we discovered that final inspection results were not being properly logged at one of our locations. We have written a CAR, but the fix will not be fully in place before our next surveillance audit. What should we do?

Just leave the CAR open and work it through as you normally would. As long as you can show you are acting to solve the problem, a registration auditor won't make an issue of it.

Environmental licenses, permits, reports?

Via phone: In our scrap recycling business we have many environmentally related licenses, permits, reports, etc. to deal with. How does ISO 14001 say we should manage these?

The ISO 14001 standard is written generically. It is not overly prescriptive and does not set performance criteria. That said: I believe that your ISO 14001 system should include a directory of all the licenses, permits, reports, etc. pertinent to your business, with a tickler of relevant expiration dates and deadlines. This way you'll assure that all license renewals, fees, required inspections, etc. are made on time.

Shear operating instructions

Via email: At our shear, there is start-up and operating instruction posted on the wall of the operations room. These are essentially the same as the instructions in our new written work instruction. What should we do about the page posted on the wall?

Rob’s answer: These types of operating instructions must be controlled. The page posted on the wall is uncontrolled at this point. If it’s really necessary to have that instruction posted and visible for the operator (and only the operator can tell you that), then it should be a controlled copy of the work instruction. Otherwise get rid of it.

Training: what must employees know?

Via phone: We are implementing 9001/14001 as an integrated system in our medium sized scrap yard. Our consultant gives us vague and conflicting information on exactly what our people need to know to survive the certification audit. Can you clarify?

Everyone in the organization must be familiar with their particular part of the system. This means awareness of, and compliance with, the procedures and work instructions that impact their jobs. They must also understand the "5 Key Facts" about the system, including things such as the policy statement, how to report quality/environmental problems, etc.

Do it yourself calibration?

Via email: We currently use an outside source to calibrate our lab and shipping scales once per year. Can we purchase our own calibrated weights and calibrate the scales ourselves? If not, can we get a member of our organization certified and if so how would we go about it? Thanks.

Yes, you can absolutely calibrate your own scales as long as the weights you use to calibrate them are certified and come with traceability to NIST standards. You obviously need to define the calibration intervals, procedure, and the amount of allowable error, and keep detailed records.

Honor Roll now includes ISO 14001 scrap recyclers

By popular demand, we have added to our Honor Roll of Registered Scrap Recycling firms all those we can identify as being registered to ISO 14001, the environmental management standard. Check it out here.

If your firm is registered but is not on the list, let us know.

How important is housekeeping?

Having worked in several dozen scrap recycling organizations, I’ve come to believe that high facility housekeeping standards make for a positive first impression. I also believe that it has a positive effect on employee attitudes and motivation.

I know what some of you are thinking: "But we’re a scrap yard!"

True. And no one expects a scrap yard to be maintained to pristine laboratory standards. But even within the context of a scrap yard, there are such things as neat, clean, orderly.

When your receiving station, open areas, machine zones, bins, metal rooms, and maintenance areas are free of clutter and litter and obsolete material, machines, and parts – with adequate signage, clearly indicated transportation routes, and demarcated areas for the staging of unprepared, in process, and prepared materials – you make a positive first impression on customers and consumers, not to mention auditors, assessors, and others who have the ability to make your life easier – or otherwise.

Scrap recyclers in particular have an ongoing public relations challenge. And maintaining your facilities and grounds in an orderly manner will, I contend, earn back in positive public relations much more than the ongoing investment you make.

It can even open the door to positive promotional opportunities. Several recyclers I’ve worked with regularly host school and civic groups on yard tours. The public is shockingly ignorant of the role scrap recycling plays in their everyday lives, and many people are fascinated to see scrap recycling in action. So by investing in regular clean-up and maintenance, recyclers can avail themselves of favorable p/r opportunities and positive word of mouth in their communities.

How to motivate executive management?

Via Email (all spelling original): /The executive mgmt level is currently of the additude that iso is just a waste of time. however they do not realize the benefits of iso in terms of improved quaility and reduced cost due to more efficient process implimentation. i am a new lead auditor and im trying to convey these benefits in a meaningfull way. how can i be more effective in motivating the executive mgmt to be more responsive to the iso system?

When top management does not perceive the benefits of their ISO system, it could be because one (or more) of the following are the case:

• They are not sufficiently involved in it. This may stem from a weak management review process, one that either does not involve the true executive management, or is a whitewash / rote exercise.
• Communication in general about the system is weak or nonexistent. Success stories need to be publicized within the organization; ditto for results of audits (internal and external), corrective/preventive action, etc.
• Most likely, there are not appropriate process / system metrics in place. Measuring the right things demonstrates improvement, traceable to the quality management system, in irrefutable form. Many companies skirt the measurement / analysis / improvement requirements, or plug in a couple of token metrics that are meaningless or stem from questionable data gathering, or smother the process by measuring too many things.

As to what you personally can do about it, I don't know that there's much you can do, except to continue to do a great and diligent job in your audits. Audits, when properly done, are the engine of implementation and improvement of the system -- assuming somebody upstairs is paying attention.

Environmental continual improvement projects?

Via Email: I have to come up with a couple of continual improvement projects for the new year for environmental. I am going to pose this to the staff for suggestions, but do you think pursuing getting rid of using styrofoam is a good project??? We use tons of it here just in coffee cups alone. I heard it does not break down in the landfills and that it is really frowned upon. What do you think? Your input is always appreciated.

Discontinuing use of styrofoam is a great continuous improvement idea. Anything you can do to reduce landfill utilization is a worthwhile effort in terms of continuous improvement. Another is monitoring of energy use and reducing it. (Track it as a percentage of sales or something else, to smooth out spikes in volume.) Many people don't realize that energy use is an environmental interaction.

Everybody hates hard hats

And some scrap recyclers actually scoff at the idea that a hard hat can prevent injury in a scrap yard.

Skeptics, take note.

Recently, at one of our client yards, a truck driver was opening the door to his roll-off box. Forty feet away, a crane was pulling scrap out of a pile. In the pile, a piece of metal scrap sprang against a trailer frame, shot straight at the driver, and hit him on the head. The impact was severe enough to drive his hard hat down into his safety glasses and split the bridge of his nose. The resulting injury required eight stitches. Had the driver not been wearing a hard hat, he might easily have been killed.

"A once-in-a-lifetime occurrence?" Perhaps. But so is death. Most of us are in no hurry.

"Just a lucky driver?" Maybe. But luck has been defined as preparation meeting opportunity. The driver’s preparation – wearing a hard hat – converted an opportunity to get killed into a manageable injury for the driver and an object lesson for all.

Tell your employees about this "lucky" driver. Use this incident to remind everyone why personal protective equipment is so essential in the hazardous scrap yard environment.

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Kantner & Company, Inc.
11338 W. Walton Road    Blanchard, Michigan 49310
989.289.6005   Copyright ©2006 Kantner & Company, Inc.