What is the starting point of this case study?
A plant certified three times over, running three systems. This is a composite case study: it brings together situations we encounter in the integrated system projects we support. The company, its customers and the figures are fictitious and given for illustration.
The company formulates detergents, degreasers and disinfectants for industry, in the Casablanca-Mohammedia area of Morocco. It employs around 170 people, in two shifts. Its activities: receiving and storing raw materials (acids, bases, surfactants, flammable solvents), cold blending in tanks, filling into cans and drums, a quality control laboratory, maintenance, dispatch, and pre-treatment of tank washing water.
System | Origin | Run by | What the review found |
|---|---|---|---|
ISO 9001:2015 | Request from a large industrial customer, the oldest | Quality manager, reporting to the laboratory | Its own document procedure and numbering |
ISO 14001:2015 | Request from a European distributor | Environmental engineer | Environmental legal register, spill plan |
ISO 45001:2018 | Request from a main contractor, after a handling accident | Safety coordinator | A second legal register, a separate evacuation plan |
The three certificates, issued by the same certification body, ran on different cycles: three audits a year, three opening meetings, three reports. With two transitions to complete before 2029, management decided to merge the systems before presenting them together at a combined audit.
How did the review measure the level of integration?
Against the seven criteria the certification body will apply. They appear in Annex 1 of Global ACI-TECH-3-008, the mandatory document of Global ACI (Global Accreditation Cooperation Incorporated, which has taken over the IAF’s role in accreditation): documentation, management review, internal audits, policy and objectives, processes, improvement, responsibilities. The review looked at the system as it actually ran, not as it was described.
Criterion | Initial state | Target set by management |
|---|---|---|
Documentation, work instructions | Three numbering systems, quality and safety instructions posted side by side | One base, one master list, integrated work instructions |
Management review | Three reviews on three dates | One review, tied to the annual budget |
Internal audits | Three programmes; the store never audited for safety | One programme by process, from all three angles |
Policy and objectives | Three policies, objectives by standard | One QHSE policy, objectives by process |
Processes | Quality process map, with an “environment process” and a “safety process” added alongside | One process map, each process with its three issues |
Improvement | Three action registers, a “QHSE risk matrix” that mixed aspects and hazards | One action register; three separate analyses |
Responsibilities | Three coordinators, no named arbiter | An industrial director as owner, a QHSE manager, process owners |
Verdict: a combined system, in the sense of the Global ACI document, not an integrated one. The riskiest point was not about documents. A new solvent had been listed by purchasing and approved by the laboratory without its safety data sheet going through the safety coordinator or the environmental engineer.
What was merged, and what remained separate?
The management layer was merged; the underlying analyses remained separate. The method followed is the one in our article on the ISO 9001, 14001 and 45001 cross-reference matrix and merging internal audits.
What was merged:
- One process map of ten processes, from management to dispatch, each with its owner and its quality, environmental and health and safety issues.
- One document control system, numbered by process, in French and Arabic for production workstations.
- Integrated work instructions. The one for unloading an acid tanker fits on one page: check of the certificate of analysis and labelling, protective equipment, check of the safety shower, unloading area valve closed and containment empty, what to do in the event of a leak.
- A single register of compliance obligations for environment and health and safety: hazardous waste (contaminated drums, pre-treatment sludge) under Law No. 28-00 on waste management and disposal, discharges, Labour Code obligations, with an owner and evidence for each requirement.
- A single emergency plan: spill, solvent fire, fumes; one assembly point, joint drills.
- A single management of change process: every new material, machine or formula goes through a three-part form, quality, environment and health and safety, before its first use.
- A single internal audit programme, action register and management review.
For chemicals, the register starts from the Moroccan Labour Code. Its Article 287 forbids the employer to let employees use products or substances liable to harm their health or safety under conditions contrary to those set by regulation; its Article 288 requires the employer to ensure that dangerous substances or preparations carry a warning of the danger on their packaging. The implementing texts listed under Article 287, such as Decree No. 2-08-528 on benzene, are added depending on the products handled.
What remained separate:
- the environmental analysis: tank washing water, hazardous waste, water consumption, accidental spills, with its significance criteria;
- the occupational risk assessment by work unit, carried out with operators: chemical risk, drum handling, forklift traffic, work inside tanks;
- customer requirements and batch release, which stay with the laboratory.
The “QHSE risk matrix” was withdrawn. It was replaced by a shared procedure on the system’s risks and opportunities, fed by the three analyses.
What governance was put in place?
An owner in top management, a QHSE manager, and process owners responsible for all three issues. The industrial director was named to arbitrate between output, safety and the environment. The three coordinators were brought together in a single QHSE function, with a manager and two leads, one for the environment, the other for health and safety.
The safety and hygiene committee (comité de sécurité et d’hygiène, or CSH) is the joint employer and employee body that the Moroccan Labour Code, Law No. 65-99, requires from 50 employees (Article 336). It keeps its legal role. Its tasks also cover the environment inside and around the company (Article 338): its minutes now feed the single action register, its annual report (Article 342) is an input to the management review, and its members take part in emergency drills.
The internal auditors of the three former systems were trained in pairs that combine specialisms. The first audit cycle was supervised by the consultancy, which did not audit alone any process it had helped to design. These courses, like those for process owners, were written into the training plan before they took place, so that they could fall under the special training contracts (CSF) of the OFPPT, Morocco’s Office for Vocational Training and Work Promotion, under the rules of the CSF procedures manual (May 2006, amended by Amendment No. 2 of 2 June 2014), with no promised amount (see CSF and OFPPT funding).
How was the combined audit prepared?
By fixing the date with the certification body, then giving it an honest description of the level of integration. After a written exchange, the certification body proposed grouping the three audits on the date of the ISO 9001 recertification, in the first half of 2028; how cycles are aligned depends on each certification body’s rules. This audit will carry the transitions to ISO 9001:2026 and ISO 14001:2026 and the ISO 45001:2018 recertification, with a margin before 30 April 2029, the end of the environmental transition set by the Global ACI transition document.
The offer received follows the rules of Global ACI-TECH-3-008: a time calculated for each standard, their sum, a reduction justified by the declared level of integration and the make-up of the team, capped at 20%, and a statement that audit time may be revised once integration is confirmed. Management also asked whether its cold blending activity could fall into a lower environmental complexity category: Global ACI-TECH-3-004 allows it for a mixing activity free from chemical reaction or emission, but it is for the certification body to decide and document. The mechanisms are detailed in our article on combined audit cost and duration.
Six months before the audit, the plant had completed a full cycle of integrated internal audits and held its first single management review. A combined mock audit is scheduled. The health and safety part remains on ISO 45001:2018, with a review planned once the revised edition is published.
What lessons for a chemical plant?
That integration is measured, lived at the workstation and planned with the certification body. Points to check in your own plant:
The overall framework is in our guide to the integrated QHSE management system for factories in Morocco.