14001: In everyone's interests

Greg Roberts looks at how organisations will benefit from the requirement in the new 14001 standard to be more outward looking

Environmental management systems (EMS) tend to be insular and defensive in their outlook. The existing EMS standard ISO 14001: 2004 and the guidance standard ISO 14004 require little more than the public disclosure of the environmental policy, a procedure to deal with complaints and, possibly, taking stakeholders into account when evaluating the significance of environmental aspects. This results in an EMS that provides incremental operational improvement, but fails to take advantage of wider lifecycle opportunities.

Many organisations are already benefiting from stakeholder engagement, however, which is often used to identify what is important to key influencers and to ensure that informed decisions are taken. Graham Sprigg, founder of IMS Consulting, has seen the benefits from this process. “The more you know about your stakeholders, the more likely you are to succeed,” he says. “Whether it’s finding out what the local community thinks is important about the way you run your plant to minimise nuisance, or what your staff feel could be done to improve your waste management plans, engagement provides plenty of valuable information.”

British Gypsum, part of the Saint-Gobain group, a world leader in design, production and distribution of construction materials, has used stakeholder engagement successfully at both the corporate and local levels. It has used online surveys to establish the views of employees and customers to develop a more intuitive sustainability strategy. Heidi Barnard, sustainability leader at British Gypsum, explains the advantage of this approach: “We know we have a leading role to play in addressing some of the enormous challenges that society faces. We engage with a variety of stakeholders in order to understand what is important to them and therefore what we should focus on in depth. Through this engagement we are able to prioritise on the correct issues.”

British Gypsum has engaged the local community around its East Leake site in Leicestershire to provide direct practical benefit. “Neighbours now have a personal contact with someone at the site for discussion, rather than historically feeling the need to raise complaints about an issue. Taking the time to meet them quarterly reduces their concerns and ensures they always have a point of contact,” explains Lorna Pilbin, environment manager at the site.

There are likely to be more examples of positive engagement after the 14001 standard is published in the autumn. It will require organisations to identify their relevant stakeholders and what these groups or individuals require from the EMS. From this information, the organisation can then determine the stakeholder requirements it needs to abide by, such as legislation, and those it chooses to observe, such as a customer objective.

Who’s interested?

An interested party is defined in 14001: 2015 as a person or organisation that can affect, be affected by, or perceive itself to be affected by a decision or activity. A person can be a single neighbour, while interested organisations can include community associations, regulators, suppliers and customers. Interested parties can be internal (as defined by the scope of the EMS), such as employees, trade unions and the senior management team. They may also fall outside of the scope the EMS but within the wider corporate entity; this will avoid situations where the design or procurement functions are ignored because they sit outside the scope of an EMS for a manufacturing site, for example.

The new standard does not require interested parties to be specifically named; rather, broad groups will suffice. However, additional value may be gained from the exercise where named interested parties are listed. An organisation should also be conscious that it is likely to be an interested party to others. For this reason, and in order to be ahead of its customers, an organisation may want to tackle the requirement to identify their relevant stakeholders early in the transition to 14001: 2015.

Requirements consist of what the stakeholder needs and what the stakeholder expects. Only relevant interested parties and relevant requirements need to be considered. For example, the Health and Safety Executive may be a relevant stakeholder because it regulates environmental related legislation, such as the EU REACH Regulation and the environment elements of the domestic Control of Major Accident Hazards Regulations.

At this stage, the expectation will be to gain a general, high-level understanding of the requirements of stakeholders, but the value gained will increase with the detail provided.

When implementing or transitioning to the new standard, a factor that contributes to success is the involvement of all functions or departments.

This is true when determining interested parties, because certain functions will identify with their own stakeholders; for example, procurement with suppliers and sales with customers. Gaining the input from all functions can be achieved through a one-to-one interview; a more valuable approach can arguably be gained from a workshop, which acts as a forum to share ideas.

In preparation for the workshop, and in keeping with the 14001 principle of integration, any previous work undertaken relating to stakeholders should be reviewed. Are they considered in strategic or communication planning or sustainability strategies, for example? If the organisation already has good information on who its stakeholders are and what their requirements are, it may not need to do more. It is also worth remembering that the revised quality standard, ISO 9001, which is also due to be published this year, and the forthcoming international standard for health and safety management systems (ISO 45001) will have a similar requirement to identify and engage interested parties. Therefore, a single overarching exercise may suffice to cover all three standards.

Working together

The workshop can be a simple brainstorming exercise or it can follow a recognised methodology, such as AccountAbility’s stakeholder mapping tool. It considers five dimensions when identifying stakeholders (see panel, p.13) and can be a good first step in drawing up a list of interested parties, after which those deemed not to be relevant can be excluded.

Although not specifically required by 14001: 2015, value will be added by listing some named stakeholders. This can help those participating in the workshop to identify with these individuals and groups and to learn about their requirements. These requirements can include the environmental objectives of a specific customer; employee perceptions of environmental performance; local community projects; and the reporting requirements of regulators. Gaps in knowledge should be embraced. The collective recognition that they exist and that everyone involved needs to help to plug them being one of the main strengths of this exercise.

A single workshop is unlikely to provide all the information needed on every interested party, so a follow-up meeting or mechanism to enable participants to give feedback may be necessary. It is worth noting that an organisation is unlikely to gather a complete picture of its stakeholders, but once the workshop group feels that it has enough information, the organisation should move on.

Compliance obligations

The next step is to consider which stakeholder requirements are compliance obligations, known as legal and other requirements in the 2004 version of 14001. Compliance obligations consist of interested parties’ requirements that are legal mandatory obligations; and those obligations which the organisation has discretion over whether to adopt. Legal obligations should be identified first, with an organisation selecting from the remainder the others it wishes to adopt. This formal process of adopting requirements allows an organisation to focus and coordinate what is important, rather than meet them in an ad hoc way.

14001: 2015 recognises the importance of communicating with stakeholders, particularly in relation to compliance obligations. Communication should be based on information generated from the EMS, which will require robust monitoring and measurement to ensure that it can be relied on. The monitoring and measurement processes will benefit from being included in the internal audit programme. In this way, an organisation can ensure that what it communicates is required and reliable (see panel, left).

Critically, compliance obligations and the requirements of interested parties need to be considered when developing environmental objectives. Some companies are already thinking about their implementation of the new standard and are setting objectives that their existing system rarely cover. These can include advising their customers on how to make their processes more efficient and investigating how end-of-life products can be taken back for recovery. Such progress will reinvigorate those stagnant EMS, which are struggling to find improvement on site.

Keep partying

The exercise to identify stakeholders and their requirements should not be regarded as a one-off. Its real value will come as it is repeated and matures from a largely “desk-top” approach into direct dialogue with stakeholders. Once organisations start to understand their stakeholders, it should become routine for the two to engage to help inform business decisions.

Sprigg at IMS Consulting explains how a company can build on the basic 14001 requirements: “The simplest approach would be to undertake a survey to understand what is important to your stakeholders. This can be undertaken by conducting interviews or increasingly through the use of online surveys.”

Prior to the engagement, it is essential that a clear purpose or objective is established, such as examining stakeholders’ views on a specific issue or its relative importance, or to gather feedback on proposed objectives. The questions posed to stakeholders need to be carefully constructed so that the answers they elicit are unambiguous and actionable. For this reason, open-ended questions should be avoided. Keep the engagement to a few major issues, perhaps to significant environmental aspects, and keep it short. Where appropriate, report back. Stakeholders will be keen to know the findings and, more importantly, the action to be taken as a result of their input.

With more than 300,000 14001 certificates worldwide, it is exciting to think of the conversations in, and between, companies that will take place because of this new requirement. Each organisation cannot deliver sustainability alone. Joint working and partnering will be a necessity and 14001: 2015 might just be the catalyst to get this party started.

Different dimensions when identifying stakeholders

Communicating with stakeholders

Requirements

Interested parties

Which of these become compliance obligations?

Communication? How, when, with whom?

Monitoring and measurement procedure

Internal audit

Greg Roberts, MIEMA, is a manager at Ramboll Environ.