ISO 14001:2015 – Lessons from the Early Adopters #2
Marek Bidwell interviews Nigel Sagar from Skanska UK about his experience making the transition to ISO 14001:2015.
The Senior Environmental Compliance Manager for Skanska UK, Nigel Sagar has worked in the construction industry for over 30 years. His career has comprised of two distinct phases; for the first 15 years, he fulfilled a site role on civil engineering projects, with the remainder having been spent in the environment department. During that time, he has written, implemented and maintained several management systems compliant with ISO14001.
With approximately 5,500 employees, Skanska UK is one of the UK’s leading project development and construction companies; it is known for major projects such as the Gherkin and Crossrail.
Skanska UK successfully completed the transition to ISO 14001:2015 in March 2016 as part of an audit by LRQA of their integrated quality, health and safety, and environmental management system, which is called ‘Our Way of Working’.
Give me an overview of how you prepared for the 14001 transition?
I followed the development of the standard through each draft as it came out, and did a Gap Analysis to compare the requirements of the standard with the contents of our management system.
The seminars and webinars that were given at the time by Martin Baxter of IEMA, who was on the ISO committee, were really helpful, as were the updates posted on the CRA Europe website by Bryan Hughes, who was also on the committee.
I was attempting to identify not only the new aspects of the standards, but also the way in which they should be interpreted – that was the hardest element.
What was the outcome of your Gap Analysis?
There was a gap in terms of high-level risk and opportunity [clause 6.1.1]. Within ‘Our Way of Working’ we have risk registers both at a company level and at a project level. Although we are always looking for green opportunities, this was not well covered in our processes, so we had to develop something to improve this.
In other areas, we needed to increase the effectiveness of what we already had in place, ensuring everything was running smoothly.
We had been using a life-cycle approach for a while, driven by the Skanska Color PaletteTM [clauses 6.1.2 and 8.1]. We are endeavouring to move all of our major projects towards ‘Deep Green’ by undertaking a colour palette assessment at the tender stage; this is then continued through the construction phase, with a final assessment at the end of construction.
We report on the percentage of revenue taken by the business split according to the three outcomes on the colour palette: Vanilla, Green, and Deep Green. The Deep Green criteria includes net zero primary energy, near zero carbon construction, zero waste, net zero water, zero hazardous and unsustainable materials, the way in which the product is used, and eventually the way in which it is adapted, reused or recycled at its end of life. In other words, it was all in place, although some aspects had to be linked more clearly back into the design process.
With regard to communication [clause 7.4], the environment team in Skanska UK has a Communications Business Partner to support us internally, and we had already implemented an external communications plan that includes events in which we participate, sponsorships, and sustainability groups on which we are represented; for example, the Business Unit President, Mike Putman, chairs the Green Construction Board. We were therefore well placed in terms of communication.
Additionally, I identified the need to formalise our process for evaluating the effectiveness of training [clause 7.2].
Another aspect of the new standard that we highlighted was defining employees’ competence to do particular things [clause 7.2]. We were using an environmental training matrix, which is categorised by job title and includes mandatory environmental courses (such as courses for procurement and design staff). However, we have further developed the competency process to include specified professional membership levels tasks. Anyone can write an environmental aspect and impact assessment, but it now has to be approved by an associate member of IEMA or equivalent; similarly, anyone can write a project’s Environmental Management Plan, but they have to be reviewed and approved by a full member of IEMA or equivalent.
Did you have any problems with the new leadership requirements [clause 5.1]?
No; historically we have had a lot of commitment from top management. Senior Skanska UK managers have always attended either the opening or closing meetings. When we conduct management system reviews, that are held in the individual business streams and feed into the Skanska UK reviews, Senior Directors attend those meetings.
Did you find that the auditor asked more searching questions of senior management during the transition audit?
We completely reversed this by ensuring in advance that a number of Managing Directors were prepared to speak to the certification body. Examples of the questions asked included, ‘How did you put your business stream 2020 strategy together? ‘How do site-based issues feed into the strategy?’ ‘What are your environmental objectives and targets?’ and ‘What support do you give to people in the business on environmental management?’ The assessor found that the Managing Directors were well versed in our environmental issues, and having that top-level support makes it much easier.
The Skanska Color PaletteTM has been in place since 2009 and is easy to understand. Our target is to get a certain percentage of our projects into Deep Green and the Managing Directors understand and promote this.
Historically, members of the Skanska UK board have had a target to give a certain number of external presentations on environmental issues at fora such as EcoBuild. This was beneficial to environment team members because it gave them an increased motivation to seek relevant information to present, which equally increased their knowledge of the issues. They easily exceeded their target, which has now been given to the next level of management.
What was your experience of the actual audit process?
It was a learning process, both for our certification body and for ourselves. Now that ISO 14004 has been published, there is a lot more guidance on how ISO 14001 needs to be interpreted.
Our auditors are covering all three standards (14001, 18001 and 9001); some have more knowledge and experience of ISO 14001 than others. Those who have an industry background are good at understanding the specific challenges we are facing.
On this occasion, they spent more time interviewing managers from our central enabling functions such as procurement, HR, design and fleet. For example, employees from the procurement department were asked about our sustainable procurement policy and designers were questioned about taking a life-cycle approach. The assessors spent a week at our head office in Maple Cross as well as visiting a selection of our projects and offices across the UK business.
What were the audit findings?
For the transition and re-certification audit, which took a total of 55 days and covered all three standards, we received only two Minor Nonconformities for ISO14001:2015, with no Opportunity for Improvements or Observations.
The first was Minor Nonconformity was related to risk and opportunity [clause 6.1.1]. We had conducted a risk and opportunity assessment at Skanska UK level, and also at the individual business stream level, as part of the development of our 2020 business plan; each issue identified is linked to one of the five strategy areas in the business plan.
When visiting a particular project, the assessor found that the risk and opportunity assessments were not in the same format as the overall business plan risks and opportunities, although there was an aspect and impact assessment and a general risk register for each project. We consider that aspects and impacts are almost 100 percent certain to happen, whereas risks and opportunities might happen. One of the key opportunities for us is taking a project into Deep Green, but we cannot do this for every project.
Another complication is that if a client wants us to use their documentation on a project we have to do so, and therefore for some projects there was no section in the documents for environmental risk and opportunity analyses. This could continue to be an issue for us when working on projects with a client who is still working to the 2004 version of the standard and we will have to agree our approach to this.
The other finding was that environmental objectives [clause 6.2.2] were not fully documented.
We have a detailed plan for environmental objectives at a Skanska UK level, but when the certification body was visiting a certain project there was not a detailed plan for achieving all of the specific project objectives – what, by whom, and when.
Do you perceive that there were any benefits for your organisation or the environment from the changes to ISO 14001?
Although we were already doing many of the new requirements, their inclusion in the standard reinforces what we are doing. The changes in the new version are very positive and are certainly a step in the right direction. This can only bring benefits in encouraging more people to become involved in environmental management, not only in Skanska UK but also in our supply chain.
The changes may also make it easier for us to obtain environmental information from other organisations in our supply chain, helping us all to manage life-cycle issues more effectively.
What advice would you give to others making the transition to ISO 14001:2015?
Undertake a gap analysis, read the newly published ISO 14004, seek advice from your certification body and speak to other practitioners who are going through the process.
What is the next step for your organisation’s EMS?
We are always looking to improve our EMS and make it more effective. Our priority in the next year is to make it more user-friendly. We will be making changes to “Our Way of Working” on the intranet to subdivide it into the different phases of the project, with the relevant processes and procedures linked to the project stages.
Another priority is to digitise more documents; for example, we intend to make documents such as inspection forms available on iPads and link them into BIM.
We are also planning to extend the use of the Skanska Color PaletteTM methodology to maintenance contracts including Facilities Management.
Through Skanska UK’s experience in the transition, we can now assist our other Business Units around the world in their transition via the Skanska ISO14001 working group, which I chair.