Canadian Environmental Auditing Association

CEAA Member Feedback on Certification Issues

We have consolidated all the responses, verbatim, for each of the issues raised.  Please take the time to review the feedback.  They have not been placed in any strategic order but simply copied from each respondent's e-mail or fax as they arrived. 

Don Fraser, Executive Director (Registrar), CEAA

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Issue # 1 - Written, formal examinations for EMS(A and LA) certification designations
Issue #2 - Discussion on revamping/revising he CEAA Auditor certification designations
Issue #3 - Value of and/or need for Standards Council of Canada accreditation of EMS Auditor designations
 

Issue # 1 - Written, formal examinations for EMS(A and LA) certification designations

We would like your thoughts and ideas on the plan to establish a written, formal examination focusing on the principles and practices of auditing primarily sourced from ISO 19011, supplemented by CSA Z773 and ISO 14001?

Responses:

1)  "I agree with CEAA is a formal exam for EMS applicants. However, existing EMS members should be grandfathered."

2)  "I feel that the CEAA should carry through on its stated intent to implement a formal examination process for EMS (A and LA) designations."

3)  "This issue appears to be tied to Issue #3. The use of written exams would appear to have more merit if accreditation is dropped. In either case written exams would appear to fall under the jurisdiction of CEAA; at the end of the day CEAA is setting the standard by which to approve or deny applicants."

4)  "Exams are probably a good vehicle for ensuring some basic level of competence, and thus some form of testing should be developed (but as a former Chief Examiner at CEAA, be forewarned that it's a lot of work)."

5)  "I believe that a formal, written exam is necessary. However, I do not believe that it must be the sole responsibility of the CEAA to administer or proctor the exam. If a prospective candidate has taken formal training such as the 5-day Lead Auditor course, then there is no reason that the exam cannot be written at the conclusion of the course, and proctored by the training institution. This would require some coordination and standardization on exam questions and acceptable answers, but it should end up being of benefit for all, and should satisfy our needs for confirmation of the applicant's knowledge.

In those cases where formal training is provided by an institution that does not have the interest or means to participate and/or where the training is obtained through a combination of courses (such as what I instruct at the University of Calgary), then the CEAA would still have to make available and administer its own exam."

6)  "I just took and passed the QMI Lead auditor course and I can state that the exam was rigorous and appeared complete.  Another exam on the same topics would be superfluous."

7)  "I feel an exam for the EMS(A) or EMS(LA) designations would be appropriate in that it gives all applicants an equal playing field on which to demonstrate their knowledge. This is more important now with many organizations doing their own training. I would suggest that existing EMS(A) and EMS(LA) designations be grandfathered. Also those individuals that have a CEA designation should not requiring the additional exam if they apply for the other designations because they have already written an exam. The exam is objective evident of knowledge."

8)  "I would support this initiative.  This is critical for the discipline to self-regulate its practitioners.  It is through this examination that the CEAA or CECAB could exclude those who fail to meet the standards for personal attributes, and those standards for the knowledge and skill and their application as auditors.

What this would entail is the development of a guidance document for both examiners and prospective auditors.  This could be similar to the engineering books for ethics (personal attributes) and law (knowledge and skill)."

9)  "I believe it is in the best interests of all involved to have a formal written examination for EMS applicants covering the auditing principles as well as the CEAA Code of Ethics."

10) "Good."

11)  "If the decision is to have written exam – fine!  But, then, drop the requirement to take a five day training course (i.e. double testing).  If someone knows their stuff, the exam will show this.  Why does it matter how they came to know it?"

12)  "In a nutshell, no.  If the EMS designations were mandated by statue or regulation, then yes but as they are not, then no.  If an exam is put in place I can foresee less people applying for the EMS LA or A designations as anyone can do EMS audits as long as they meet 19011 (unless a particular organization, such as a registrar, has so mandated that the auditor hold a designation, see Issue 3 below).  We should be encouraging applicants and maintaining the quality through the screening process.  Does not the 14001 Lead Auditor course, including the exam, need to be accredited by appropriate bodies?  That should cover off the exam requirement.

The ABCFP does have an exam, typically 6 hours.  The exam covers two areas, code of ethics/bylaws and practical.  However, the practice of professional forestry in BC is governed by the Foresters Act.  The practice of EMS auditing is not governed by any act or regulation at this time.

The CGA does not have an entrance type exam; however there are exams tied to 18 individual courses that need to be taken during the 4-10 years it takes to become a CGA.  A degree is required before the designation is issued, but not before enrolling in the program.  Again, professional accounting is highly regulated compared to EMS auditing."

13)  "I agree with idea of a formalized process to confirm an applicants knowledge and competence to conduct audits.  If all training and examinations were conducted by CEAA it would be easier to determine the level the applicant has achieved; however a formal written examination (either as part of a training program) or conducted separately should close any gaps that may exist."

14)  "A formal exam for EMS(LA) and EMS(A) is not required as long as the training is provided by a Registrar and a written exam is completed and passed by the candidate.

It would be better to have a specific ethics exam such as is done by the PEO, this would then apply to all designations.

ISO 19011 states that evaluation can be done by one or more of the methods listed in Table 2, testing is just one of these methods and it is not necessary that it be used.  The “Positive and negative feedback” is a good method to obtain information regarding the ability of the candidate.  A method such as this was used in the early days of the CEA certification.  We could solicit input from the auditees listed in the audit experience part of the application." 

15)  "Lead Auditor Courses already require candidates to write an exam.  These courses are offered by accredited registrars and are audited by the accreditation organization.  As applicants are required to have applicable training, I would think that this exam (which in my opinion as a former instructor of such courses is rather grueling) would be adequate."

16)  "Long overdue."

17)  "There should be a CEAA exam.  Several of us took the KPMG/Jacques Whitford course a few years ago and I found their exam at the end to be credible, but we could easily see a lot of inconsistencies between course providers.  Also, if more people took the exam, they could see themselves as closer to be "certifiable" (in the good sense!), and may become CEAA members."
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Issue # 2 - Discussion on revamping/revising he CEAA Auditor certification designations

Do you agree that CEAA should pursue revamped/revised auditor designations? What is your feedback to the proposal?

Responses:

1)  "I agree that CEAA should revise auditor designations."

2)  "Yes the CEAA should proceed to revamp designations.  As always the devil will be in the details, however, in order to maintain relevance, CEAA designations need to keep up with developments.  That said, the audit PROCESS should be the same for any type of audit - in many ways the conduct of an environmental compliance audit is identical to a financial audit is identical to an H&S audit is identical to an EMS audit - establish the "benchmark", interview, collect evidence, draw conclusions, prepare factual and objective report.  The place for differentiation is in the understanding of the benchmark / standard that one audits against."

3)  "Absolutely not. None of my clients have ever expressed a need for such specialized auditing services; in fact my experience would suggest that most industrial clients are incapable of distinguishing between EMS auditors and CEAs. Creating more/new designations will heighten this confusion; this agenda appears to more of a "make-work" program by CEAA, maybe to justify their existence, or increase revenues."

4)  "I don't see the need for more/specialized designations.  Our field is already so specialized that most people (including many clients) have never heard of some of the three designations (CEA, EMS and EMS(LA)).  Other professional bodies don't develop specific designations at lower levels (e.g.. P.Eng., C.A.) to describe areas of specialty, but instead rely upon experience as the appropriate arbiter in the marketplace.  When combined with the cost of developing and implementing more designations, I think this is a poor path to choose."

5)  "Yes, I believe that the CEAA must move with changing standards and the needs of the marketplace. However, change just for the sake of change is never good. There needs to be some good reasons to make the changes, because any change will be time-consuming, will always upset somebody and may become expensive. The CEAA should think this one out very carefully, and be sure to keep the membership well informed."

6)  "Yes I agree. Based on your explanation of the issues it would appear to make sense."

7)  "I was interested to see that there is interest in H and S auditing. From years of personal experience, I have too often seen this emerge primarily as "S" auditing with no or little attention paid to the "H" side of things - or at least the "H" side as viewed by an OHN or Occ Doc. I sincerely hope that the deliberations in this area have involved some of our CEAA members who are also OHNs and Occ Docs."

8)  "I firmly believe that the most valuable internal process - as a check of the effectiveness of management systems, as a check on implementation of company and legal requirements, but most importantly, as a tool for continual improvement - is the integrated EHS (and ?Q) comprehensive audit. Many organizations perform this activity every three years at operating sites and every 4 - 5 at office sites. It usually follows generally accepted audit principles and therefore would meet auditing standards. From my perspective, there is a need to move ahead with standards for comprehensive integrated EHS auditing."

9)  "I feel that the existing designations are adequate. Any changes to the designations will cause confusion. Most other professional organizations do not change their designations every few years. (e.g. CA, PEng)  The designations CEA, EMS(A) and EMS(LA) have been accepted by most industries utilizing environmental auditing services. Changing designations may also result in changing criteria which means people who currently hold designations may not meet the new criteria.

The exam may need to be updated but that is more house keeping than requiring a change in designations."

10)  "I would support the addition of the certification for the compliance auditor.  This is particularly important given the changes to ISO 14001:2004.  I have done both EMS and compliance auditing and it seems that EMS auditing improves with experience.  Compliance auditing does not.  This discipline requires assurance that the auditor is up-to-date in his/her knowledge of relevant statutes and their applicability.  Too often external auditors waste company resources in false-positive identifications in audits, and I feel this needs to be addressed through an assurance process.  This could require annual training requirements in the relevant health/safety and environment legislation, where guidance is given to people on the application of the legislation as well as the intent."

11)  "I think there is a need to update the requirements for the 4 Auditor designations but I do not believe that we should change the actual designations.  If there is a need for some additional knowledge or skills to meet current standards then that should be identified in the certification process.  If the issue is critical to existing auditors then perhaps a process would need to be put in place to ensure that existing auditors upgrade accordingly to maintain their status."

12)  "I agree that the CEAA should look at new and/or revamped designations.  However, the mandate of the CEAA is Environmental Auditing, not QMS, H&S or others that may be out there.  I think the focus should be on aligning/updating the current designations to reflect changes (i.e. 19011, does there really need to be a split between EMS LA and A?).
As I do not have the CEA or CEA(SFM) designations and do not foresee applying for these in the near future, I do not feel qualified in offering constructive opinions on these."

13)  "Yes, but  reciprocity with other programs would be most welcome and beneficial.  The clients do get confused when we “string” a multitude of initials behind our name.  The cost is becoming prohibitive to maintain a “host” of certifications."

14)  "If we have to have a “made in Canada” program, then, yes, we should pursue these designations.  However, with Canada having 30 million people, a relatively low number of management systems in place and with RAB, IRCA, IEMA, etc., etc. I wonder if all the effort is really necessary.  Perhaps it is nice to have – but is it worth all the effort?"

15)  "I agree that the CEAA should look at new and/or revamped designations.  However, the mandate of the CEAA is Environmental Auditing, not QMS, H&S or others that may be out there.  I think the focus should be on aligning/updating the current designations to reflect changes (i.e. 19011, does there really need to be a split between EMS LA and A?).
As I do not have the CEA or CEA(SFM) designations and do not foresee applying for these in the near future, I do not feel qualified in offering constructive opinions on these."

16)  "Whole heartedly agree with a proposed review of the current auditor designations to keep up with changes that have occurred with ISO 19011, and to keep up with changes and programs in place both at home and internationally.  My teams currently conduct a complete risk management audit (1st party) that includes Health & Safety looking at both conformance and compliance.  We are finding that now that these management systems are in place and are implemented and through a couple of cycles, a more focused risk based approach is becoming necessary.  Our client is asking for that type of review, and it makes good business sense for us to tailor our process to accommodate the changes both internally and externally."

17)  "The CEAA should revise the auditor designations.  We should be basing the designations on ISO or national standards unless there is a strong need for a unique and focused designation such as CEA(SFM).

I would caution against creating too many designations for environmental auditors or combining environment with other subject areas as this could limit the ability to work in other sectors.

We should have designations that meet the requirements of ISO 19011 and, in the absence of an international standard on environmental compliance auditing, CSA Z773-03.  This should serve us well in other countries.  The designations would be:
? ISO 19011 EMS(LA) 
? ISO 19011 EMS(A) 
? CSA Z773 Environmental Compliance (LA) 
? CSA Z773 Environmental Compliance (A) 
? And so on if we want to get into other areas.

As I stated in Issue #1 exams are not always needed.  That said, as a marker for both the oral and written CEA exams, the CEA exams certainly need to be re-written.  The goal should be to establish a large question bank so that the exams can be varied.  The exams should be written once or twice per year at locations across the country with current CEA’s acting as proctors.

While I am a CEA and it is a uniquely Canadian designation, it goes beyond any standard and may not be needed.  I t could be changed to cover the two lead auditor designations listed above.

In regards to industry and business expectations mentioned the experience and continual education we need to recertify should take care of these issues."

18)  "This is a huge undertaking.  I agree that auditing has evolved since the CEA designations were introduced.  I also agree that we need a certification system for H&S auditors.  I am not sure what value there would be for the other distinctive designations suggested."

19)  "Yes - revamp"

20)  "We like the idea of "conformance" type auditor and a "master" level auditor that includes skills in risk-based auditing, includes H&S and effectiveness approaches to auditing."
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Issue # 3 - Value of and/or need for Standards Council of Canada accreditation of EMS Auditor designations

Let us know if we have characterized it correctly and thoroughly. What has been your experience(s). What do your clients feel. Do they see value in the accredited certification. Do they understand the difference (if any) between an accredited and non-accredited certification? Would the accredited certification be perceived as more valuable if SCC marketed it to industry/business? If so, what perspective or values should SCC focus on?

Responses:

1)  "I audit for a Canadian Registrar and as far as I know I require that CEAA maintains the SCC accreditation so dropping it is telling me that you don't want me as a member.  I find this quite disheartening in that the expectation when becoming a member in the first place was that the certification would be accredited. So this is changing the agreement in mid-stream, which is akin to Ford telling me that the warranty on my car will no longer be honored.

I believe that the root cause of the financial issue is that CEAA did not establish an EMS auditor and EMS Lead Auditor designation until a number of years after it started up and as a result many Registration Auditors went to RAB for certification because they could not meet the extra requirements of the CEA designation.  We are paying for that loss of membership revenue now and by tossing out the remaining Registration Auditors we are not helping anything.  To me we should be putting on a campaign to attract these auditors back – the end result may be reduced CEAA fees for everyone (volume spreads the fixed costs thinner) in addition to having the money to maintain SCC accreditation."

2)  "My clients do not understand the difference between an accredited and non-accredited certification.  Not a concern for them."

3)  "From the information provided, it does not appear to make sense to get the accreditation."

4)  "This issue appears to be tied to issue #1. I personally feel that it does, however I do not feel strongly on this issue."

5)  "As a consultant/auditor not working for a Registrar, I see zero value in SCC accreditation, and encourage CEAA to drop it.  Outside of the Registrar's needs, the marketplace does not know about it, care about it, or recognize it.  Let the Registrar's fund it or fix it, and save the money at CEAA."

6)  "And now you have hit upon my pet peeve. I find it exceedingly unfair that all certified auditors have to pay dearly for the exclusive benefit of 16% of our number. For first and second party audits, industry cares only that the auditor is certified. As long as the certification scheme and organization is credible, that is all they want. They don't even know about the SCC accreditation.

As for the registrars, it seems that we have set up a reverse trade barrier. Our certified auditors are disadvantaged by high certification fees while others practice freely in the country. Does this make any sense? Has SCC accreditation made our auditors any better than the competition? I think not. 

Can the CEAA maintain and improve its certification QMS without the SCC? I think so, as long as we have a committee of the Board whose mandate is to do so. There are alternatives, and we should explore them. The SCC needs to realize that its rules are hurting, not helping the auditing profession in Canada."

7)  "I am not a registrar and do not intend to become one.  My clients do not see a value in the accredited certification.  A non accredited designation from the CEAA would serve me as well."

8)  "I believe there is a need to continue certifying folks who can act as external auditors for organizations requiring management system certifications by a third party."

9)  "SCC accreditation is not a requirement for myself or my organization. When we hire auditors we require CEAA designations - depending on the tasks. While the SCC accreditation is hid in the background it does not add value to the tasks performed by the auditors for my organization. The only time the SCC topic ever comes up for me is reading about it in one of the CEAA newsletters or emails. Prior to the inception of the EMS(A) and EMS(LA) accreted designations the CEA designation was widely accepted across the country. At first glance the EMS(A) and (LA) designations appeared to be a quick way of receiving a designation without the effort that goes into the CEA designation."

10)  "I believe that there is value in the accredited certification in that it is an “arms length” process outside of the CEAA.  Although not necessarily required for all projects there is always the potential there and the costs associated with losing a contract due to not having the certification in my opinion outweigh the cost of maintaining the system.

As an auditor with both CEA and EMS(LA) designations I am a little disturbed by the costs that are discussed in the article.  I have just recently paid a total of approximately $600 for my CEAA membership and maintenance.  Given the number of 180 auditors from the article that equates to $108000.  In my mind the business case for the accredited certification is OK.  If you are going to questions this then you might as well question the costs (and hence business case) for CEAA’s CEA designation. Do all companies that are hiring auditor services require CEA's?  Do all government contracts for environmental auditors require CEA's?  I believe the answer to both those questions is no however there is still value in the designation and the required membership that goes along with it. It is simply a cost of doing business in this sector with an associated value that is difficult to measure."

11)  "Currently I require an EMS (A & LA) as I audit for a registrar.  I do not believe clients know the difference between an accredited and non-accredited certification because it is the registrar who makes the requirement, not the client.

SCC should market it to the clients."

12)  "I think you have characterized the issue correctly; however, I raise (again) the issue of does it have to CEAA being accredited?  If needed, a registrar auditor can be certified to an accredited scheme such as RAB, IRCA, IEMA (I believe), etc.  Does CEAA really need to go through this added effort and expense – or is it a luxury that is neither needed nor affordable?"

13)  "I say stick with it.  It has helped in my business (although, like certified forest products, I can not charge extra for my EMS-A!) as I have been doing the promoting of the benefits to my potential clients myself.  I question the accuracy of the 30 EMS LA and A who have to have the designation.  I have a registrar as a client and I do third party audits as a subcontractor for them.  They require all their contractors to have the EMS LA or A designation, so you need to count these people as well.  I suggest the number may be a bit higher than 30.

SCC and/or CEAA need to take a more active role in explaining the benefits of using certified auditors.  Articles in trade publications, like the ABCFP’s Forum magazine, would help, as would presentations and booths at AGMs and trade shows.  Leaving it up to the individual members will result in a scattered approach with possibly conflicting information being presented.  As a good first start, I would suggest the SCC and the CEAA collaborate on a brochure explaining the process and the benefits.  This brochure should be easily obtainable (through the web) and easily understood.  EMS LA & A's could then use it to supplement their own marketing activities.

If the CEAA chooses to drop the SCC accreditation for EMS LA & A, then I would see no reason for continuing my membership with the CEAA.  That is the value I place on my EMS-A."

14)  "I would think that the accreditation would in some way add value to the certification of an auditor, however a good point is made with respect to CEA designation not being accredited but still being credible.  As an uncertified (accredited or not) auditor, I have no experience to draw on in this respect, and my due to the nature of the operations my clients would not understand the difference; certification is not a requirement."

15)  "It has not been my experience that accreditation by the SCC adds any value.  When the CEAA first started providing CEA designations, auditees I dealt with felt that an auditor having a CEA had met requirements set by an outside body familiar with environmental auditing and as such had added confidence in the results of the audit.  Since that time the reputation of our organization has grown and the designations we provide have even more meaning and this would not diminish if we did not use the SCC.

Given that we must not abandon our 30 members that need the SCC accreditation."

16)  "For the most part, most of my clients have not requested that I have any designation (CEA or EMS(LA), however, some are impressed with the designations, once they understand what they are.  I don't think that the SCC accreditation adds any value, for my purposes, however, I am not a registrar auditor.  I believe that we first need to educate clients on the values of CEA and EMS(A or LA), period, and why they should be sourcing auditors with these designations.  Once that value is perceived, then we should worry about the SCC accreditation."

17)  "Environmental auditors not certified via an accredited scheme should not be allowed to conduct environmental client audits in Canada. 

"Clients think all auditors with CEA & EMS (A or LA) or other credentials are accredited auditors"

"Accredited certification is necessary. Market it better to industry/business".

18)  "We believe the CEAA 'certification' has sufficient credibility, so don't really see need for CEAA to go through SCC process.  Others in our company don't even know the differences.  Just want to maintain the ISO 14401 registration credibility in the public."
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Last updated on ... Janaury 30, 2023