14001: fit for the future?

13th March 2012


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IEMA

With the global environment management standard being revised, Paul Suff hears how it should change

ISO 14001 was last revised in 2004 and the process is now under way to change the standard so it remains relevant and effective until at least the middle of the next decade.

Last November, member bodies of the International Organisation for Standardisation (ISO) voted in favour of revising the standard in line with advice from the environment management system challenges study group, published in 2010.

The revision will examine all 24 of the group’s recommendations, including strengthening requirements examining transparency and accountability in regard to environmental management, clarifying environmental management’s contribution to sustainable development and, potentially, aligning the language with that used in ISO 26000 – the corporate social responsibility standard.

In February, the environmentalist and consultancy WSP hosted a roundtable event to discuss whether the proposed revisions are sufficient to help organisations make a step change in environmental performance improvement and ensure the standard helps them meet future environmental challenges.

Participants were also given the opportunity to discuss wider aspects to improve environmental management, namely the quality and value provided by third-party audits.

An opportunity

“The scope of the revision is quite broad. It’s a real opportunity to put a standard in place that is fit for the next 15 years or so,” says Martin Baxter, director of policy at IEMA and national expert on the revision of the standard, opening the discussion.

He highlights the shifting emphasis in the revision proposals, away from 14001 focusing almost exclusively on operational impacts on the environment, towards helping organisations manage the effects of a changing environment on the way in which they do business.

“Potentially, that gives them a much closer alignment between the environment and business strategy going forward,” he says.

Baxter acknowledges that such a transformation presents significant challenges for people who are engaged with 14001, whether they are responsible as environment professionals for environment management systems (EMSs) in their organisation, or externally auditing. “It provides a very different context, but when you look forward to 2025 and the challenges that we face, I think 14001 has to live up to that challenge.”

He believes environment professionals are generally positive about the shift. Since the start of the year, IEMA has been hosting workshops on the revisions throughout the UK and Ireland, attended by more than 400 members. Baxter says the feedback from members is focused on supporting 14001 to take on the new role.

“They think it will add value and help organisations better meet the environment–business dynamic and the challenges going forward. There is a very clear support for aligning management systems, and 14001 EMSs in particular, with organisations’ overall strategy,” he explains.

“That has implications for the way in which organisations might structure and use management systems.” In future, EMSs are likely to push more into supply chains and the way in which products and services are designed, developed and produced, says Baxter.

“It’s about a move from greening operations to greening organisations across the value chain and the role 14001 should play in that.”

Several roundtable participants express their support for the planned changes to 14001.

“I’m encouraged by the proposed revision and think it actually provides an answer that Yorkshire Water, as a company, has been looking for,” remarks Miles Foulger, environment strategy manager at the water company.

“I would say that the existing standard is fading in its usefulness to us as a business. Our EMS is well embedded and is taken very seriously, but it’s very much focused on compliance and meeting a standard in procedures. What I like about the proposed direction of travel in the revision is its focus on planning for the future.”

“I think it’s paramount that the standard takes a broader approach going forward,” says Geoff Court, group health, safety and environment adviser at printing and marketing business St Ives. “It needs to encourage more continuous improvement from a sustainability point of view, rather than, like now, just ticking boxes confirming you have the right procedure in place.”

WSP’s Eve Peverley also believes the revision needs to make helping organisations improve their performance a priority. “For me, one of the key things is to focus on the commitment to continuous improvement. How can that be pushed forward? I know linking 14001 with sustainability and the wider supply chain is important, but I think for organisations that have already bought into the 14001 approach, how to improve the process of continuous improvement is key.”

Treading carefully

Others are more cautious about the proposed changes. “I certainly agree that 14001 needs to move forward, and needs to be more forward-focused,” acknowledges Viki Bell, global portfolio manager for sustainability at BSI.

However, she questions whether an EMS can actually help “green” organisations. “It can be the catalyst or the lever to raise awareness of the need for organisations to change,” she says.

“But organisations come to 14001 from different ends of a spectrum: some because they want to and others because they have to. If 14001 were to become too holistic, too loose and not specific enough, many in industry wouldn’t like it.”

Similarly, Kirsten Holman, senior environment consultant at Parsons Brinckerhoff, the professional services arm of the Balfour Beatty Group, feels the proposed changes may potentially put off some organisations, particularly, small and medium-sized enterprises (SMEs).

“I think the current standard is still a very useful tool for many of the companies I worked with, many of which are SMEs. They already find 14001 daunting, so adding the word ‘sustainability’ may discourage them from setting up an EMS,” she warns.

Court too doesn’t want the revision to diminish what, he believes, is a key advantage of the 2004 version, which is the way it can help an organisation to build an EMS from scratch.

“I think the way the standard is currently set out is good; it has nice ‘hooks’ in it to help you easily develop your system. Any new standard needs to be able to help organisations similarly construct their systems without too much effort, so you still know where you are in the standard.”

Likewise, Peverley says: “14001 as it stands provides an excellent framework for organisations that haven’t got an EMS in place.”

Several participants raise concerns that the revision could mean that 14001 risks losing its flexibility, which they say is one of the main things that makes it such a well-respected and increasingly popular standard – there are now more than 250,000 14001 certificates spread throughout 155 countries.

“The existing standard is flexible and straightforward and we shouldn’t lose that,” warns Paul Simpson, head of brand protection at oil and gas industry consultancy GL Noble Denton. “It says identify your ‘aspects’ and, based on that, you identify those that are significant and put in place controls to manage them.

"They provide the foundations for legal compliance. Even if an organisation’s significant impacts change, the existing structure enables your EMS to be automatically updated and upgraded. Retaining that flexibility is crucial.”

Bell agrees. “The existing standard has a lot of strengths and a lot of flexibility,” she says.

Strengthening weaknesses

Despite a degree of support for parts of the current version of 14001, most participants concede that there are problems, and the standard needs strengthening in a number of areas.

“I think there are certain key clauses in the current standard that need strengthening in some way,” says Ben Vivian, co-founder of the Vivian Partnership. “The most obvious one to me is 4.4, on resources, responsibilities, roles and authority. It’s incredibly loose and incredibly difficult to assess.

"As a consequence, organisations are not being challenged about their failure to put in place adequate resources, which leads to a failure to make continuous improvement, which leads to not having the right people doing the right tasks, for example.”

As an auditor, Peverley says: “Auditors may come across cases where there is a lack of resources channelled into the EMS but they can be on very contentious ground to raise this as an issue. Allocation of adequate resources is a fundamental part of establishing and implementing an EMS and therefore must still be central to 14001, and indeed have more focus.”

Baxter points out that there is a focus on resources in the revision plans. “The extent to which organisations have the skills and competence to run an effective internal process to drive environmental performance improvement is something that needs to be looked at.

"From an IEMA perspective, the environmental skills map and our focus on developing the capability of people professionally is geared towards that. What a commitment to allocating resources actually means in 14001 is a very valid question. I would like to see it tightened up.”

Another area that needs strengthening is the role of employees in the standard. That is the opinion of Simpson. “One of the most powerful visits I made to an organisation with 14001 was a company in Northern Ireland,” he recalls

“Yes, it had ticked a lot of boxes and clauses in terms of awareness and competence. But it had also actually got people involved. There was real buy-in from the workforce into how they could help identify and make improvements.”

Vivian believes the internal communication requirement in 14001 needs to be stronger.

“Part of the problem is that communication is hugely misunderstood in the standard. It doesn’t talk about engagement or consultation. It doesn’t use those sorts of terms. It’s very much an old-fashioned-style ‘command and control’ approach – a ‘thou shalt do as I say’ approach to communication,” he observes.

Vivian advocates a more consultative approach. “Communication can simply mean a newsletter that you give out. Consultation is something that you get back.”

Peverley points out that the health and safety standard 18001 talks about consultation, not just communication.

Court highlights another advantage 18001 has over 14001. “We encourage all our managers to attend an IOSH course, but not all our managers have attended an environment management course,” he explains.

“The 14001 auditors do not really look for that, but 18001 auditors do. The latter would take a sample of the managers and ask them what courses they have done. That doesn’t happen with 14001. The auditors are satisfied if the key personnel have done the training.”

Baxter argues it’s not the responsibility of a standard or external auditor to ensure widespread environmental training, but someone internally driving that forward. However, Court believes it would be a good barometer of how far the EMS is embedded in an organisation.

According to Vivian, legal compliance is another area of the standard that needs strengthening. “We work under an incredibly complex legal system, with hundreds, if not thousands, of pieces of legislation,” he remarks.

“I would challenge anyone to demonstrate competence over such a plethora of legislation. There’s a degree of guessing and a degree of ‘over-egging’ in meeting compliance.

“I’d go so far as to say there are no organisations that are 100% compliant. The reality is that 100% compliance is almost impossible to demonstrate and almost impossible to maintain on a long-term basis.

“So what the assessors and the system need to demonstrate is that things are being picked up before they go horribly wrong. I think the processes need to be better to demonstrate compliance.”

While agreeing that a management system cannot guarantee future results, Baxter comments: “An organisation should recognise its compliance status and be managing that, and doing something about it. It’s that active management of compliance that’s the key.

“I think there is a reasonable acceptance about what 14001 can, and cannot, do to support compliance. That is, it should help an organisation to comply. And the whole purpose should be that an organisation should be able to demonstrate its compliance status at any time without having someone externally – whether that’s a regulator, a certifier or a member of the public – saying you’ve got a breach.”

A stagnant system?

Most roundtable participants have extensive experience of 14001 and many claim that the current standard lacks robust measures to maintain momentum. “I think people feel it has stagnated a little. So, it needs rejuvenating,” says Peverley.

“I agree the standard has possibly stagnated, but it’s still a growing one, both in the UK and elsewhere,” argues Bell. “For those who have worked with 14001 for a very long time, you can see where its boundaries and problems lie, but there are people at the other end of the spectrum who are just starting out. It’s not stagnant for them. It’s still a very active standard for them in terms of establishing an EMS.”

“I think the stagnation is more the way 14001 is being used and assessed,” comments Vivian.

Toby Robins, sustainable development director at office supply company Wiles Greenworld, says part of the problem is that the existing framework fails to actually drive improvement. “The fact that you can have auditors coming in and just finding the slightest improvements, which they consider is sufficient, is a weakness.”

Robins believes that 14001 provides a very solid foundation for organisations’ environmental efforts, but asks why other standards such as the Carbon Trust Standard, for example, can provide a way to easily quantify improvement and 14001 doesn’t.

Several participants want auditors to demand more improvement from companies. “I do feel that with my own company we’ve got the 14001 badge, and we get it every year,” states Holman.

“We’ve actually challenged our auditors and said: ‘We want to use the auditing exercise to improve, so push us’. We simply weren’t being challenged enough. You can have a very small amount of improvement and still get your certificate. We would like them to demand more, so we get more out of what is really quite an expensive process.”

Baxter, however, challenges whether 14001 is failing to drive improvement.

“If you ask IEMA members if the standard has helped their organisation improve its environmental performance, they will all say yes,” he claims. “Having said that, there is a question about whether it goes far enough and fast enough, and whether it is ambitious enough. I think that comes down to a series of internal drivers.

“If you are being told you need a 14001 certificate to supply, that puts a different dynamic on your pursuit of certification compared with an organisation that is using it to develop a leadership position on the environment. There are many different motivations for seeking 14001 and we shouldn’t lose sight of that.”

Robins counters by saying: “I appreciate many organisations say 14001 has delivered improvement. If you ask whether implementing the standard improves performance, I would agree. But I’m now in the position where 14001 is no longer driving improvement.

"That’s the problem. I keep it as a marketing badge to differentiate the company from others. That’s the wrong way round. It should be driving improvement and it should be something to be proud of.”

“If you go through all the clauses and tick all the boxes, then that’s where you are, but it doesn’t encourage an organisation to do anything more,” says Court. “It’s down to environment professionals to drive improvement.”

Discussion moves on to how best to drive improvements in mature systems. The ISO study group on environment management system challenges recommends the use of maturity matrices – an organisational assessment tool – to show how the requirements of the standard can be applied in an increasingly comprehensive manner.

Baxter says that IEMA members are keen on incorporating maturity matrices – first included in BS 8900, Guidance for managing sustainable development – in the revised 14001 standard.

“A matrix can help an organisation plot where it has embedded an EMS and environmental thinking into the way in which it does business,” he explains. “And environment professionals see that as a real opportunity internally to drive improvement and differentiate.

“The point about a maturity matrix is that it would enable an organisation, and whoever is responsible for the EMS, to maintain momentum. It’s about improvement that delivers and provides value in terms of environmental performance,” he says.

Bell agrees that such instruments can be beneficial. “At a revision meeting I attended a couple of weeks ago looking at the 8900 series and 26000, the feedback from industry representatives was that the one very useful part of the system was the maturity matrix,” she says. “It was the one tool they could use and implement, and really get some benefit from.”

Simpson, however, offers a note of caution. “If I’m honest, there’s not much interest so far in ISO 9004, where a maturity matrix is also used, so there isn’t very much evidence of organisations moving along a maturity matrix.”

“I think one of the reasons they have not caught on is that they only really exist in the 8900 series at the moment, and that series is in its infancy compared with the 14000 and 9000 series,” comments Bell. “There’s not much exposure to maturity matrices, but they were the one part industry was keen to hang on to.”

The role of auditors

Irrespective of the proposed changes to the 14001 standard, the role of third-party assessment will be crucial to how much real value organisations gain from certification. And the revision of 14001 comes at a time when the environment profession is engaged in debate about the value and quality of third-party audits.

One thing that irks environment professionals is the lack of consistency among auditors. “My concern is that I’ve seen a number of systems recently where there is real inconsistency in how they are audited,” observes Vivian.

“We’ve looked long and hard at whether we’re working with the right auditors. Are they rigorous enough?” says Foulger. “Really, what this comes down to is who is the standard for and what purpose and outcome does it serve? Our main driver is what we, as a company, want to achieve. The audit and certification process just provides a degree of assurance. However, I would agree that it is an imperfect process.”

Court offers the following example: “We’ve got three different audit companies across our group, because we’ve got four different certificates. They each interpret things differently. I have one auditor say one thing and I’ll go to another site and the next auditor will say something almost completely different ... even though the end result – that both companies in the group are managing a particular aspect well – is the same. We pushed back on that. We have actually changed auditors at one of our sites as a consequence.”

Vivian likens auditors’ differing readings of 14001 to how rugby union referees administer the rules of the game. “There are a set of rules and they are open to interpretation by the referee, so you get different outcomes. It’s the same with 14001. And, if that’s the case, where’s the standard?”

“From an auditor’s point of view, they’re more concerned with us complying with their interpretation of the standard,” says Court.

The national standards bodies should be asked to provide the definite answer on interpretation in a particular context, but that service is rarely used.

“If more organisations used this facility you wouldn’t have the problem of two audit bodies giving conflicting advice,” says Baxter. “Trouble is, it has never really been used in the UK, but it is used in other parts of the world. We’d like to see more organisations use that mechanism.”

A major concern among roundtable participants is whether, in light of the proposed changes to 14001, auditors, many of whom are already struggling to satisfy clients, will be able to effectively assess companies against a standard that may embrace sustainability and is more closely aligned with business strategy.

“The skill set is completely different for compliance-type compared with more strategy-based audits,” says Bell. “BSI operates the Kitemark Energy Reduction Verification (ERV) scheme and auditing companies’ performance requires a completely different skill set from compliance auditing.”

Vivian agrees. “The concern I would raise about moving to a more strategic standard management system is that you end up in a situation where you’re asking who’s going to audit it? Who’s competent enough to audit? So, if you end up with a system that no one can actually audit, either internally or externally, you’ve got a big problem.”

“Certification is completely outside the scope of the revision,” notes Baxter. “14001 says it’s a matter for the organisation what type of accreditation service or process it employs.” He does, however, believe that organisations could do more to vet their auditors to ensure they are competent.

“I don’t see why businesses do not say: ‘If you’re going to come and work on our site and look at our management system, I expect you to be at least as good as I am’. Why would I want someone who has less knowledge or experience to come and tell me how well, or not, we’re managing our environmental impacts?”

Baxter also believes IEMA could provide some assistance. “I think there is a role for the Institute in articulating the sort of questions organisations should be asking certification bodies,” he acknowledges. “Let’s get the market moving behind it. And, with 15,000 members, IEMA is in a great position to drive that.”

the environmentalist and WSP roundtable took place on 7 February at WSP House in London. WSP and the environmentalist would like to thank all those who took part. Thanks also to David Symons for his excellent work chairing the discussion.

Roundtable Participants

David Symons (chair) – head of global sustainability business practice at WSP
Martin Baxter – policy director at IEMA and UK national expert on the revision of ISO 14001
Toby Robins – sustainable development director at Wiles Greenworld, an office supply company and SME
Geoff Court – group HSE adviser at printing and marketing business St Ives
Ben Vivian – co-founder of the Vivian Partnership consultancy
Viki Bell – global portfolio manager for sustainability at BSI, the business standards body
Paul Simpson – head of brand protection at GL Noble Denton, a consultancy focusing on the oil and gas industry
Miles Foulger – environment strategy manager at utility company Yorkshire Water
Kirsten Holman – senior environment consultant and EMS manager at Parsons Brinckerhoff
Eve Peverley – member of WSP environment management team


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