Auditor John Marsden gives his assessesment of the environmental management standard, which was first introduced in 1996
Most people involved in environmental management will regard 1996 as a key year in raising the standard of management systems and processes. That was the year ISO 14001, the international standard for environmental management, was first published. Now, 15 years later, about 230,000 organisations worldwide have the standard.
The 1996 blueprint contained management techniques, requirements and guidance on how to systematically improve the environmental performance of an organisation and was based on the earlier British standard, BS 7750. Fifteen years on, how have organisations interpreted and implemented these requirements, and has the standard been successful in improving environmental performance?
Going forward
Back in the early 1990s, environmental concerns were largely confined to heavy industry, where evidence of visible pollution was all around. Steelworks, chemical factories, foundries and coking plants dominated the industrial skyline of the UK and other developed nations.
In some areas of the UK, the recessionary hangover from the previous decade had left a significantly degraded industrial landscape marred by spoil heaps, coloured rivers and grimy buildings.
Scientists were also aware of other, less visible, yet serious manifestations of pollution arising from chemicals, such as polychlorinated biphenyls, chlorinated solvents and pesticides. In addition, the far-reaching implications of greenhouse-gas emissions were becoming recognised within the global business community.
The scale, power and impact of the commercial sector provided the ideal platform with which to start the process of improving the environment. National governments set out requirements in the form of legislation, fiscal policy and other means that could be applied to industry by regulators and this process has been ongoing.
Environmental management system (EMS) standards, such as 14001 and the European eco-management and audit scheme (EMAS) were developed to provide the necessary guidance that would help the business sector understand what it had to do. The links between the EMS and environmental legislation clearly needed to be strong and 14001 was designed to facilitate the implementation of these laws.
From the point of view of its creators, 14001 required a carefully worded document that would be seen by environmentalists as a standard that could deliver significant benefits and improvements. On the other hand, users wanted to see a mechanism that could fit with existing management system frameworks, such as the quality standard ISO 9001, together with a format that was not too difficult to understand and implement. A balancing act between these two sides had to be maintained because 14001 is not a legal requirement in itself and could not be forced on organisations.
The huge carrot dangled in the face of industry was that a certificate of conformity to 14001 would be a desirable and coveted prize, and a reward for the effort required to develop a management system aimed at satisfying a relatively uncharted business driving force – the environment. Some degree of financial payback to participating organisations could also be regarded as part of the incentive framework. Energy efficiency and waste minimisation are two commonly cited benefits from having 14001, although measures to improve these issues would probably have been implemented anyway, especially during regional and global recessionary cycles.
The activities of the accreditation and certification bodies also had a part to play, providing a level playing field on which the certificates of conformity to 14001 could be distributed and managed. Their role as referees should also be considered when judging the overall effectiveness of the standard.
The numbers game
Answers to the following broad questions can be used to measure the degree of success of the standard and provide guidance on the future direction of EMS developments.
- Has 14001 been widely accepted by industry and commerce?
- Has it enabled significant improvement of environmental performance?
- Has it improved compliance with applicable legislation?
- Has it encouraged cooperation between business and the local community?
Over the past 15 years of implementation by organisations, the acceptance of 14001 as a business standard has been widely acknowledged. ISO – the international standards organisation – now feels confident enough about the level of uptake to claim that “14001 has achieved a truly global status and is thoroughly integrated with the world economy.”
Not only is the number of certifications globally edging towards a quarter of a million, the pace of the uptake appears to be accelerating: the total number of certificates awarded rose from 150,000 at the start of 2007 to 225,000 in spring 2010. So something must have hit the mark.
Some certificates include a number of operational sites within the scope of a single certificate and this may increase the actual number of sites towards the 250,000 mark. Compared with the European standard, EMAS (just under 8,000 sites were EMAS certified at end of March 2011), the 14001 numbers are impressive.
However, compared with the more than one million certificates now issued to the quality standard 9001, the uptake of 14001 still has a long way to go. Regardless of this, the potential anticipated in 1996 for 14001 seems to have been realised, especially when it is noted that most of the big corporate organisations of the world now see the standard as a “must have”.
For them, the need for a management system based around 14001 provides a clear and consistent framework for employees who may be spread across the globe. Communications, documentation management, training and internal auditing are important processes and 14001 helps to provide a degree of consistency in their applicability to environmental issues.
Smaller organisations
Further down the supply chain, the small and medium-sized enterprises (SMEs) of the world have been less willing to develop an interest in accredited certification. The most probable explanation for this is that time, cost and a low perceived environmental impact have all played their part in dampening a desire to develop a full EMS. Many decisions are made by just a few managers and staff who are in close contact most of the time, so for them environmental aspects such as waste management, energy efficiency and packaging tend to be controlled within informal procedures rather than a formal system.
Over the years, other standards have arisen that provide their own twist to the specification for EMS, aimed in particular at the SME sector. In the UK, the Acorn Scheme – based around BS 8555:2003 – seems to be popular with some companies. About 640 companies have subscribed to this approach, with 146 currently on the register.
However, these numbers are hardly likely to impress the impartial observer, especially when it is realised that they include companies that have just started the journey, or have stepped off on the way. So much for staged implementation. Yes, there are examples of effective improvement of environmental performance, but what is worrying is the number of companies registered only in phase 1 (setting policy) to phase 3 (setting objectives) of 8555. This means that they do not have to implement anything or achieve actual improvements to their environmental performance to gain a level of approval. At least the presence of a 14001 accredited certificate demonstrates that the organisation has all elements operational at the same time, much like a fully functioning website without any broken links.
The publication of ISO 14005:2010 provided the somewhat bemused global SME sector with an internationalised version of the above standard. This in itself has generated negative comment and rejection by CEN, the European standards board. All this seems to fly in the face of the original concept surrounding the development of a single, internationally acceptable standard for environmental management.
Back in the 1990s, the proliferation of different national standards provided the logic for developing a unified and consistent approach, yet, 15 years on, the pendulum seems to have swung in the opposite direction.
The clarity of 14001 is being eroded by the confusion generated by the standards industry and its political machinations. On a personal level, the knowledge that 14001 could be applied to organisations of different sizes, sectors and complexity helped me to realise that underlying business processes are largely very similar. I still believe that the adaptability of 14001 has played a major part in its success.
Environmental success?
So, has the presence of a certified EMS in an organisation resulted in a significant improvement in environmental performance? It is almost impossible to provide a clear answer to this question as the development of environmental regulation and non-legislative initiatives have taken place at the same time. However, without the structure and framework that is provided with a full EMS, organisations would find it difficult to coordinate and manage these improvements.
Again, from a personal perspective, the large number and variety of organisations that have been audited indicates that improvements need to be tracked and managed in a coordinated manner in order for them to stay on track.
One recent example involved an audit of a component manufacturer that had not developed a proper strategy to address its packaging compliance requirements. The whole system was in disarray because responsibility had not been set at board level. Further down the hierarchy, personnel on the shop floor were carrying out haphazard monitoring of packaging weights and, although the information was communicated to the relevant compliance scheme, it had been very difficult to obtain. The certification audit assisted them to address the issue and quickly get back on track.
For the past two decades, legal compliance has been a key driving force for organisations. The need to maintain compliance reduces the amount of time “wasted” by senior and middle management fighting court cases and compensation claims; the loss of corporate reputation can sometimes be devastating to the credibility of a business or brand. This potential risk has probably increased since 1996 and the introduction of 14001.
The standard has been revised only once during its lifetime – in 2004 – and mainly to create a separate clause for the evaluation of legal compliance. In other words, this requirement has become even more important than before.
Experience shows that many 14001-compliant organisations really do understand how to identify legal requirements and include them in their legal register (clause 4.3.2). They also periodically evaluate their degree of compliance to the laws specified (clause 4.5.2). However, there are also many other companies that do not understand this process. For them, the legal register remains a jumble of current and outdated legislation. Some applicable requirements are missing and the relevance to the organisation is sometimes vague and unspecific.
Responsibility for legal issues cannot be set and the threat of legal non-compliance remains as high as ever. So, after 15 years and one revision, why has 14001 performed below expectations in such a critically important area? One reason may be the lack of emphasis on legal training for key personnel involved in the running of an EMS.
The same could be said of the certification auditors who periodically visit the organisation to carry out an audit. The accreditation system seems to work reasonably well, but how many auditors would be weeded out during a rigorous assessment of their understanding of environmental law? It is all too easy for auditors to steer themselves away from the complexities of environmental permitting, hazardous waste management or the packaging regulations and onto more familiar territory, such as management review and setting objectives and targets.
UKAS – the UK accreditation body – does have a system in place for shadowing the work of auditors while a certification audit is being conducted, but somehow the number of issues relating to environmental legislation is still higher than expected.
Greater demands should be placed on the auditor community to demonstrate its understanding of environmental law – and not just in the comfort zones they may specialise in. After all, if the auditor is not firing on all cylinders, how can the organisation?
The interface with local communities on environmental issues seems to have made significant improvements in recent years, although, again, it is difficult to tease away the strands that contribute to this improvement.
14001 demands that communication processes with outside agencies and bodies are sufficient to enable a dialogue to take place. Pressure groups, local community groups and individuals are now able to exert an influence on the relevant business activities of a 14001-certificated company. One recent visit revealed the extraordinary lengths to which a manufacturing business went to address a problem with a nearby property with respect to a connected sewer pipe. That would have been unlikely several years ago. A publicly available environmental policy, together with auditable communication procedures, contributed significantly to this process.
Sum of its parts
So, after 15 years of implementation, what is the current position of 14001? Certainly on the world stage, the standard has developed an impressive track record in terms of numbers of certificates. It has also probably influenced the development of numerous unregistered EMSs, together with other standards offering broadly similar outcomes. Regulatory recognition has developed over the years as the Environment Agency now includes any company that can demonstrate a “robust EMS” in its compliance assessment plans.
However, this success is tempered by the need for improved standards of certification, better auditors and a greater focus on legal compliance and improvements in environmental performance. Still, there is no reason why the standard cannot continue to offer a fair and reasonable framework for improving the environmental performance of organisations well into the future. At least for the next 15 years!
Acorn Scheme participation
IEMA would like to clarify that participation in the Acorn Scheme is dependent on an organisation implementing one or more phases of BS 8555, having this confirmed by an independently accredited Acorn Inspection Body and then demonstrating continuous environmental improvement on an annual basis to that inspection body.
