ISO 14001:2015 – Lessons from the Early Adopters #3
Marek Bidwell interviews Kyle MacNeill from the train operating company Northern about their experience of making the transition to ISO 14001:2015.
Northern is the largest train operator outside of London. It provides more than 2,500 services every day and serves a network of 15 million people. Operating a fleet of 333 trains, it also manages 475 stations. Currently, Northern (formerly called Northern Rail) is at the start of a new franchise run by Arriva, which commenced in April 2016.
Northern Rail was the first organisation in the world to be certified to ISO 14001:2015 on 15th September 2015, by certification body NQA.
Kyle MacNeill has been the Environmental Assurance Manager for the organisation since 2012, since which time he has administered Northern Rail’s Environmental Management System (EMS) and acted as Northern Rail’s advisor for compliance, pollution prevention and nuisance.
How did you prepare for the 14001 transition and how much work was involved?
We did a Gap Analysis when the Draft International Standard came out, with the aid of your guide ‘Making the Transition to ISO 14001:2015 – From Compliance to Opportunity’.
Luckily for us, our NQA auditor was appointed as their lead person working on the transition, so during surveillance visits prior to the transition he was helping us to look ahead. However, we found that we had already implemented most of the new requirements.
What were the strengths of your existing system?
We developed a tiered management review process about three years ago [clause 9.3]. This approach allows management teams at different levels of the business to review, and contribute to, environmental performance.
In 2012, when Northern Rail’s franchise was extended for two years, we performed a context analysis as part of our environmental strategy development [clause 4.1]. The resulting actions were devolved across the business, rather than being solely the responsibility of the environmental team, and the MD chaired the top group, signed everything off, and was involved in the analysis.
Dr Karen Booth, who was then our Head of Sustainability, led the context analysis, facilitated by a former Environmental Director from another train operating company. The actual work was done by our Environmental Review Group, which was comprised of the heads of each directorate across the business. The idea behind the analysis was that if we were devolving all these actions to the business, and expecting them to deliver, they needed to help create that vision. The analysis took into account people’s perceptions and opinions on the risks and opportunities available to Northern in terms of the environment, and the risks to the environment with regard to Northern.
Because ISO 50001 (for energy management) had already been delivered by our Energy Solutions Manager at the time, Gareth Williams, we had already established a process to capture energy opportunities, which we had extended to all environmental opportunities, as part of our integrated energy and environmental management system [clause 6.1.1]. We also had a way of identifying and grading aspects that could have a positive impact on the environment.
Regarding life-cycle thinking, we had reviewed our procurement processes to prepare for the BS 8903 standard, looking at the social, environmental and financial aspects of sustainable procurement. The Procurement Team was already on board and embedding life-cycle thinking into their processes, and two of our procurement managers were assigned to work on this [clause 8.1].
What did you identify as the main changes you needed to make?
We were measuring contractual requirements with the Department for Transport and requirements from the ROSCOs (rolling stock operating companies), such as the requirement to use only certain coolants on the trains. Going forward, however, we started to capture other non-statutory compliance obligations, such as noise complaints associated with public address systems, whereby local managers made commitments either to shut engines down, or to ensure that public address systems were turned down. This was hugely advantageous to us because previously local managers had made commitments and then left the company, so that the complaints would arise again and the residents would have more information than we did; but now we do know about it and the process is more resilient [clause 9.1.2].
We also developed a process for identifying environmental risks to the business, such as flooding, landslips and track buckle associated with climate change. Each incident associated with these issues has been pinpointed on a map of the network, allowing us to identify hotspots. In the new franchise, therefore, we will be able to start focusing our adaptation work and investment in these areas, working collaboratively with our industry partners [clause 6.1.1].
What were the audit findings?
We had a corrective action against policy [clause 5.2c] – this required us to add a commitment to the ‘Protection of the Environment’, replacing the wording we had previously used, which was ‘Enhancement of the Environment’.
There was also a linked observation to amend the commitment ‘to improve environmental performance’ to incorporate a commitment ‘to improve environmental performance and the management system’ [clause 5.2e].
The other corrective action was associated with our ongoing audit programme [clause 9.2.2], which assesses operational control and elements of the environmental management system throughout the year. Whilst many of the changes we had made to the system until mid-2015 had already been subject to an internal audit, further changes had been made within the last six months that had not been captured. We therefore had to conduct an additional audit of the final changes with regard to the new requirements of the standard.
What led to you becoming the first to achieve certification against the new standard?
NQA conducted our transition audit based on the Final Draft International Standard (FDIS). When the final version came out on 15th September 2015, a comparison of the FDIS and the final version was made to identify any differences between the two documents that would fundamentally change the outcome of the audit. Because there was very little change, if any, we received a non-UKAS certificate initially, which was upgraded to a UKAS certificate once NQA had been accredited by UKAS for the new standard in November 2015.
Were there any benefits for your organisation, or for the environment, as a result of the changes to ISO 14001?
Yes, especially with the life-cycle work becoming a requirement of the ISO standard, because it gave us a great push to get things done. Even though we had already been working on it, we ensured that those changes were embedded prior to the standard being published. It also helped us to integrate the life-cycle thinking within project planning.
The new high-level assessment of environmental risk means more to the executive, and integrates with our business risk management system, which is discussed at a high-level Business Review forum.
Our MD has now embedded health, safety and the environment within the balanced business scorecard, so that all of the managers now have these criteria as part of their personal review process.
As more people implement the requirements of ISO 14001: 2015, the changes may also help us to obtain environmental information from our suppliers. We have always found it difficult to get detailed information about our scope 3 carbon emissions. Until now we have had to estimate those emissions, based on our spending in each industry sector. We are now targeting our top, high carbon contracts, to get specific carbon information.
Hopefully, the changes to 14001 will mean that suppliers will have this information readily available, as many more customers may be asking for it; currently, we are being asked to pay extra to receive it during the tender stage.
What was your experience of the transition audit?
When we retendered our certification contract about three years ago we also re-evaluated our needs. We wanted to incorporate added value audits to look at the management commitment from directors, through heads of department, to front-line management. The aim was to gauge levels of commitment at each level by asking questions such as:
Do you know that we have an EMS?
Is the EMS working for you?
How are you improving environmental performance?
Do you understand your environmental risks?
What environmental messages are you passing down to your staff?
Are you recording environmental issues in team minutes and project plans?
Our external auditor saw value in doing this, but the old standard limited his ability to raise findings in this area – this has changed with the new standard.
What questions were asked of directors during the transition audit?
The certification body checked that our environmental risks were flowing up into the Business Risk Register and the Environmental Review Group (ERG).
The assessor asked our MD, “How do you make sure that everyone who needs to deliver on the environment does so?” This allowed our MD to talk about resourcing and the environment being an essential part of our balanced scorecard criteria (good customer service, happy people working for you, a safe and sustainable environment). That is his vision for running a railway, so it is already part of his mentality.
The assessor also asked, “How do you make sure that your managers adhere to EMS requirements?” The MD said that every manager has to undergo a performance development review that includes a safety or environmental initiative; he also explained that all directors are held accountable for safety and the environment in their area.
Did the auditor spend time with other relevant departments, such as purchasing?
Yes, he interviewed both the purchasing and the estates teams.
What advice would you give to others making the transition to ISO 14001:2015?
Conduct a gap analysis of where you are at the minute, compared to the requirements of the new standard.
Create a summary for your Board of Directors, and ask them to delegate what needs to be done. That might even include some high-level actions such as specific directors taking accountability for specific areas such as design and procurement.
What is the next step for your organisation’s EMS?
There are still lots of things that we want to do.
After we achieved 14001:2015, we developed a forecasting system for environmental objectives, which uses environmental information gathered from hundreds of locations within the business such as stations and depots. This means that, rather than simply reporting ‘we have produced x amount of waste each month’, we can forecast how far ahead or behind we are likely to be at the end of the year, taking into account a variety of factors. We can therefore effect additional changes during the year if we are going off track, or at least have an early warning system [clauses 6.2.1 and 9.1.1].
The next thing we will be looking at is integrating our system with health, safety and crime.
Currently, we are awaiting a huge investment, because we are at the start of a new franchise run by Arriva. We are hoping to do a lot of work towards improving biodiversity, which is a big opportunity for us because of our geographical range.