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Introduction
While numerous successful models of ISO 9001, ISO 13484, ISO
14001, OHSAS 18001 and other management systems were developed
and are being used in various industries, approaches to
documenting management system structures for multi-location
enterprises are limited at best. This article discusses a method
for establishing a top-level documentation structure that allows
a business with multiple facilities to use common management
system policy and manual. This significantly improves
consistency of the corporate message regarding quality,
environmental, health & safety and other policies, while
reducing the number of documents within the organization’s
management system.
Current practices create inconsistencies
Through my work as a Lead Auditor with major registrars, I
observed dozens of large multi-location companies struggling
with connecting their corporate policies and manuals with the
supporting, location-specific documents. To develop a manual for
a company with numerous facilities, organizations take two
routes. Some companies create site-specific manuals either as
copies of the corporate manual or site-specific manuals that are
different from the corporate manual.
In the first case when a site-specific manual is a copy of the
corporate manual with modifications specific to a given site,
mechanisms to keep these documents coordinated with the corporate
manual are rarely defined and followed. Difficulties of keeping
these documents in sync are due to the fact that corporate
manuals are controlled by the home office, while local manuals
are responsibility of site’s documentation control departments.
Another approach organizations take is to allow their satellite
locations having their own quality, environmental or other
policies and manuals independent from the corporate policy and
manual. This technique very often leads to major disconnect of
the corporate and local policies and manuals. From the corporate
identity and simply business consistency points of view, an
organization should not find itself in a position of having
different or conflicting commitments of its facilities to
quality, environmental issues, customer satisfaction, safety
hazards and other requirements of applicable standards. One of
our large customers demonstrated this point well. The corporate
quality policy and manual addressed majority of the requirements
of applicable standards and referenced appropriate regulations.
At the same time, one location did not reference required ISO
13485 standard, another missed a commitment to compliance with
regulatory requirements, yet another one failed to document
their quality policy all together!
As we can see, both approaches to creation of location’s manuals
as copies of the corporate manuals or independent manuals do not
appear to be practical. Besides, if a company has already spent
time on developing a manual, why should another employee in the
same organization spent more time to create a similar or
duplicate document?
Common manual can be used by all locations
To address this issue, let’s review, as an example, ISO 9001
quality manual model, specifically supporting document reference
structure and the application clause. As a common practice, a
manual references supporting documents within the text of the
manual. For example, clause 5.5.1 of the manual, Responsibility
and authority, may read:
QW Enterprises, LLP’s Management Team ensures that the
responsibilities and authorities are defined and communicated
within the organization per the Resource
Management Procedure and the
Organizational Chart.
The same model will also work for a multi-site organization for
those documents that are used at all locations. For example,
such processes as Management Review, NC-CAPA Procedure,
Documentation Management Procedure, Audit Procedure, and others
may be the same for all locations and therefore be referenced in
the quality manual as shown above. However, what if our
locations have different exclusions, use their own
organizational charts, product realization procedures, and other
site-specific documents? If we use the model above and want to
keep a common manual, we have to reference in the manual
corresponding documents for all locations which may not be
practical.
Below we will explore how a corporate manual can practically
reference location-specific documents to support commitments of
the company’s common manual. Let’s start from referencing
documents. The same reference structure as for a single-location
company can be used if the number of locations is small, let’s
say two or three. In this case, clause 5.5.1 of our corporate
manual may state:
QW Enterprises, LLP’s Management Team ensures that the
responsibilities and authorities are defined and communicated
within the organization per the
Resource Management Procedure,
Organizational Chart HO and
Organizational Chart Ontario.
This example shows references to the common Resource Management
Procedure and site-specific organizational charts for the Home
Office (HO) and the Ontario locations. While this model works
well for a limited number of facilities, it becomes impractical
when the number of locations is significant.
Manual Reference Matrix
For companies with a large number of locations, where we need to
reference numerous documents including those controlled by
satellite locations, we have another option. We can establish a
document to connect corporate manual commitments with the
site-specific supporting documents. Let’s name this document a
Manual Reference Matrix and consider the following document
reference structure:
Corporate Manual element
> Manual Reference Matrix Table of Contents (ToC)
> Site-specific Manual Reference Matrix
> Corresponding
site-specific document
To illustrate this model, let’s document the same element 5.5.1
of our corporate manual with references to site-specific
organizational charts:
QW Enterprises, LLP’s Management Team ensures that the
responsibilities and authorities are defined and communicated
within the organization per the Resource
Management Procedure and site-specific organizational
charts per the Manual Reference Matrix ToC.
This statement tells us that the company uses common Resources
Management Procedure and site-specific organizational charts. To
locate a site-specific organizational chart, we need to refer to
the Manual Reference Matrix Table of Contents (ToC). This table
of contents is simply a list of all locations’ Manual Reference
Matrixes, as shown in the illustration below:
Manual Reference Matrix Table of Contents
Home Office (Denver,
Colorado, USA)
Ontario (Canada)
St. Petersburg (Russia)
Guanajuato (Mexico)
Port Williams (Chile)
… etc,
Following the hyperlink “Ontario (Canada)” we will find a
site-specific Manual Reference Matrix. Locating element 5.5.1 in
the Ontario Manual Reference Matrix, we will find that Ontario
location uses for this clause of the manual a document titled
Organizational Chart Ontario. A
Manual Reference Matrix may be formatted as a three-column form
as shown in the figure below:
Now, when we successfully resolved the issue with referencing
site-specific documents, let’s see how we can address different
scopes, exclusions and other similar elements. Let’s say that
our corporate office maintains an integrated management system
compliant with ISO 9001:2008 and ISO 14001:2004 standards. The
corporate office management system satisfies all requirements of
ISO 9001 standard and therefore does not declare any exclusions.
At the same time, our Ontario facility is certified to ISO
9001:2008 only and does not perform design function, therefore
excluding design from its scope of certification.
These
differences can be documented within the same Manual Reference
Matrix. Section 1.1, Purpose and scope of the matrix references
ISO 9001:2008 and ISO 14001:2004 standards for the corporate
office, while Ontario facility references only ISO 9001:2008.
Similarly, element 1.2 of the matrix, Application, states for
the corporate office: “Application, QW Enterprises LLP’s
Management System satisfies the full range of requirements of
ISO 9001:2008 Standard.”, while for the Ontario facility this
element reads: ”QW Enterprises LLP’s Ontario facility does not
perform design function, therefore, design is excluded from the
scope for this facility.”
Controlling Manual Reference Matrix
It is a good idea to make your Manual Reference Matrix ToC a
part of your Corporate Manual. It is also beneficial to control
your Manual Reference Matrix Template through the corporate
documentation management system to ensure consistency of the
matrix format used by different locations. Each of your
facilities will use this template matrix to document their
site-specific references addressing requirements of the
corporate manual.
After completion of the Manual Reference Matrix by a given
location, this document, as any other, will be given a document
title and be released through the local documentation change
process. Any changes to the corporate manual should trigger
review and, if necessary, changes to the Manual Reference Matrix
Template and Manual Reference Matrixes of all locations.
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