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 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.