PAS 99: a framework for
partial integration
Three years ago PAS 99 was published to fill a potential gap in the market. However, with no revision in sight, asks if the specification has passed its sell-by-date.
At the time of PAS 99’s publication, there was a great need for practical informed guidance on designing and implementing integrated management systems. Many organizations attempting to comply with more than one management standard were recognizing common elements in different standards and that they could use some existing procedures generically, widening their scope to new areas.
However, this understanding of integration is only one step beyond the initial naïve stage of thinking that protecting people and the environment, achieving quality products and achieving commercial success are so diverse that they should be managed separately by those with specialist knowledge and in a non-uniform way. This second stage of awareness sees partially integrated management systems as possible, but is blind to the possibility of fully integrated management systems and have been implemented.
PAS 99 reflects this second stage thinking. It assists with consolidating some ‘common’ requirements in management system standards, as if there are requirements that cannot be managed in a consolidated way. PAS 99 does not support a third stage of awareness, where an integrated management system can contain a full plan-do-check-act categorization that can cope with any management requirement contained in standards or legislation, without individually addressing specific aspects of an organization’s performance, such as health and safety.
Filling a void
PAS 99 was a reactive approach to creative managers who were using joined-up thinking and integrating their approaches to management. However, it did not anticipate that this was only a first step on the integrated management systems path and that third-generation management systems that are fully integrated would be the next evolutionary development. The principal focus of PAS 99 is how to handle multiple standards rather than how to structure a complete understanding and hierarchical classification of an organization’s processes, ensuring everything has a natural place.
The specification is also a response to the standards and certification industry which fails to deliver a fully integrated management standard. Indeed, the industry continues to publish a never-ending array of standards, often with variations of terminology. The latest ISO 9001 revision, for example, made no gestures towards aligning its structure with ISO 14001.
Value for money?
So, is the guidance in PAS 99 sound and does it offer value for money? Sadly, the specification leaves a lot to be desired. It does contain some useful material, such as its glossary which encourages us to use a unified management language. However, some terms are out of date, for example it uses the term ‘interested party’ rather than ‘stakeholder’ - the term used in the ISO risk management vocabulary.
In the main sections, the specification attempts to create a structure of common management system requirements, presumably to pave the way for a future standard. Although, based on the plan-do-check-act cycle, it fails to understand the difference between the development of controls in the ‘plan’ phase and the implementation of those controls in the ‘do’ phase. The ‘do’ phase controls need to be comprehensive and include organization structure, roles, responsibilities and authorities that PAS 99 erroneously places in the ‘plan’ phase. It also doesn’t make clear that the ‘check’ part of the cycle can be both reactive and pro-active facilitating lagging and leading indicators.
Advice in the appendices is sporadic, frequently non-existent and sometimes ill informed. For example, one risk management scale of likelihood spans from ‘very improbable’ to ‘fairly regularly’ rather than quantitative measures such as ‘monthly’ or ‘yearly’. Surely, the quality profession preaches that values should be capable of being readily measured?
PAS 99 also confuses ‘tolerable risk’ with ‘low risk’ and its place in the hierarchy of risk – misunderstanding a major cornerstone of risk management thinking. However, risk does better than quality which does not even appear in the terms and definitions and nothing is said about the relationship between ‘quality’ and ‘risk’ although positive risk gets briefly mentioned. Will all future management be expressed in terms of risk?
What is needed?
PAS 99’s biggest problem is that it perpetuates the myth that fully integrated management systems are not possible. Therefore, it should be urgently withdrawn or replaced with something supporting third generation management systems.
BSI’s motivation to create PAS 99 may or may not have been commercial, but withdrawing it is probably not seen as an attractive option. Hopefully, more enlightened values will prevail and the rapid implementation of third-generation management systems will not be impeded. No army can resist an idea whose time has come!
About the author
Ian Dalling is the director of Unified Management Solutions and chair of the Chartered Quality Institute’s Integrated Management special interest group. Contact the group at imsig@thecqi.org
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