Do HSE Management Systems Audits Support Regulatory Compliance? Not So Much…

A recent survey in the UK continues to demonstrate the gap between technical regulatory compliance and HSE management systems conformance.

An article published in the June 2013 the environmentalist (the journal of the Institute of Environmental Management & Assessment, or iema) provided a short overview of research results that compared accredited certification bodies processes and “whether third-party audits of an environmental management system (EMS) could provide sufficient assurance of a firm’s legal compliance”.

The findings:

the competence of [EMS] auditors is generally limited to assessing the presence of procedures.

Clearly, assessing the mere presence of procedures is not the same as evaluating the content, adequacy, appropriate or effectiveness of those procedures. Not even close.

There was a notable divergence in opinions on the perceptions of how well EMS audits address regulatory compliance. Not surprisingly, 92% of the certification bodies were convinced their audits reflect regulator conclusions very well or quite well. Yet the regulators themselves hold a far different view with only 17% saying EMS audits address regulatory compliance very well or quite well.

We would call that a gap.

The article is also available online for iema members and subscribers.


2 thoughts on “Do HSE Management Systems Audits Support Regulatory Compliance? Not So Much…”

  1. It is a mistake if one expects registrar EMS auditors to determine regulatory compliance. Registrar auditors are not in the position to determine regulatory compliance as they do not have attorney client privileges. In addition, they are only evaluating compliance of the Management System and not regulatory compliance. One needs to think twice if they really want registrar auditors determining their regulatory compliance.

  2. I have been into Management System assessments for more than 12 years. I would agree with the opinion regarding gap. Although I fully agree that there are limitations to which a Management System Assessor can take Regulatory Compliance alone as a Decision Making criteria, they can surely assess much better in terms of checking the status of compliance. A requirement of ISO 17021 regarding Competence of Assessors related to Country of Audit Skills has a potential for improvement in its implementation by Certification Bodies and checking by Accreditation Bodies. My experience has been that many of Accreditation Auditors who come to Assess ISO 14001 process of Certification Bodies have primarily ISO 9001 background. Hence, a greater emphasis and time is spent of Auditor Selection for Sector Qualification (based on SIC, NACE or T-Codes) rather than Environmental Subject and Regulatory Knowledge. The whole purpose of hiring Technical Specialists for Overseas countries gets lost in that.

    We can surely improve the quality of ISO 14001 audits to reduce these gaps despite all the limitations and should work towards that.

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