The new 14001 standard requires senior managers to do more to promote environment management. What will this mean in practice? Paul Suff reports
The latest version of ISO 14001, the international standard for environment management systems, is expected to be unveiled after the summer.
As the environmentalist went to press, the working group developing 14001: 2015 was meeting in Tokyo to discuss the feedback on the draft standard (DIS), which was approved by 92% of member bodies of the International Organisation for Standardisation (ISO) late last year. Although there are likely to be some last-minute tweaks, practitioners know pretty much the core content of the new standard and how it differs from the 2004 version. One area that is noticeably different and which is likely to make a positive difference is the greater emphasis in on organisational leaders playing an active role in the environment management system (EMS).
An explicit reference to leadership was absent from 14001: 2004. Clause 5 of the revised standard, however, is devoted to leadership and includes a raft of requirements to which those at the highest level in an organisation must adhere. Senior management will have to demonstrate leadership and commitment with respect to the EMS by, for example, being accountable for its effectiveness and for ensuring that it achieves the intended outcomes. They are also responsible for establishing, implementing and maintaining an environmental policy that is appropriate to the purpose of the organisation and its context – such as the nature, scale and environmental impacts of its activities, products and services. Assigning EMS roles and responsibilities is also the function of senior management.
Top management will no longer be able to simply delegate to a representative key elements of the EMS and consider that an end to their involvement. Delegation remains permissible and senior managers are not required to perform every action themselves but, importantly, the top team is accountable for ensuring that they are performed.
Many environment professionals welcome the new version’s greater emphasis on those in senior positions taking responsibility for the EMS. Sandra Norval, head of environment at Southern Railway and Govia Thameslink Railway, says: “There is a big opportunity here for forward-thinking organisations to begin to use their systems in more creative ways, more in line with the original intentions of the standard. We are still in a rut of organisations using systems to tick the environment box.”
To many, like Andrew Edlin, group environment and sustainability director at food business 2 Sisters, the 2004 version is dated. “The 2015 edition has definitely raised the bar,” he says. “It is tougher and more challenging, and has addressed some of the criticism levelled at the old standard in terms of integrating environmental considerations into organisational decision-making and ensuring environment management is not a marginal activity.”
Others regard the clauses on leadership in the 2015 version as pivotal to improving the performance of management systems. Greg Roberts, environment consultant at manufacturers’ body EEF, says that successfully meeting all the new requirements in the revised standard depend on top management taking accountability for the EMS. “Leadership and commitment are fundamental to success,” he says. “Currently many systems have little support from senior managers. Arguably, it is the requirement for leadership and commitment in the revised standard that organisations should focus on first.”
Clare Dann, global technical manager for environmental management systems at BSI, describes the new leadership features as a big change. “Leadership has always been in 14001, but now it will be much more explicit. Leadership flows through the whole of the revised standard, which should help raise the profile of the EMS.” Martin Baxter, executive director at IEMA and a member of the working group revising the standard, is pleased that 14001: 2015 now specifically defines top management and what it is accountable for. “This undoubtedly strengthens the role of senior management in an EMS. There will be an expectation on executives and directors to make sure management systems are effective.”
Levels of engagement
So how will top management respond to the challenges posed by the revised standard? A gap assessment by EEF in 2014 found 80% of the 800-plus organisations examined had insufficient top-level support to meet the requirements of 14001: 2015, while in 42% of cases senior managers had little or no involvement in their company’s EMS. Environmental and safety legislation advice service Cedrec polled just over 200 practitioners last year on the revised international standard and found that nearly two-thirds (62%) of respondents were unsure how the changes would affect their organisations. The results revealed that strategic management involvement and leadership, and lifecycle thinking were the two biggest areas of concern with 14001: 2015.
Despite the findings, many practitioners are reasonably confident that their top management teams will cope with the transition from 2004 to 2015. Edlin reports that several divisions at 2 Sisters have been certified to the 14001 standard for a number of years and that its leadership team is committed to the system. He believes this longstanding support will mean the top management at the company will easily be able to demonstrate the requirements in clause five of the revised standard. “We’ve got a culture of leadership engagement with the environment at 2 Sisters, which will stand us in good stead,” he says. Likewise, Kirsten McLaughlin, company environment manager (UK) at consulting firm Parsons Brinckerhoff, says her senior management team is engaged on the environment. “We have a sustainability action plan that runs to the end of 2015, which was signed off by the leadership team. A member of the sustainability team reports to top management quarterly and senior managers sign off the management review of the firm’s EMS,” she explains.
Independent environment consultant Anya Ledwith at ESHCon also considers the new standard an opportunity to embed environmental management more effectively. “It’s what the profession has spent the past 20 years striving for,” she says. But, she warns, that this might only happen in organisations that already see the value of using 14001.
Edlin also suspects that organisations without the same level of top-level commitment might struggle at audit to show how senior management is delivering its functions under the new 14001. This lack of ongoing support for the standard among top management in some organisations is a theme taken up by Roberts at EEF: “Many EMS have little support from top management. This is largely down to the business case for the EMS not being fully understood or articulated beyond the need to have the 14001 ‘badge’. Too frequently, after certification has been achieved, the system is left to stagnate, with small incremental operational improvements. Strategic vision is absent and the organisation misses out on driving real business value from their EMS. Many organisations are therefore not ready for transitioning to the new standard.”
Norval agrees: “In my experience many systems have been delivered by keen individuals managing upwards, merely endorsed by those at the top level, so this will potentially prove to be a challenge in some organisations.” She believes that, because the new iteration of the standard is much stronger in its requirements for genuine leadership from top management, this will help move away from structures where the “environment” is seen as a standalone team, and where all relevant tasks and issues are simply diverted to those designated as responsible for it.
Dann at BSI offers a similar view: “Top management will no longer be able to pay lip service to a commitment to the management system. They will have to demonstrate, for example, how they ensure the environmental policy and objectives are compatible with the strategic direction and the context of the business, and where they are explicitly involved.”
Raising awareness
Baxter believes the degree of engagement by top management will depend largely on the messages delivered by environment practitioners. “The revised standard provides further impetus for practitioners to engage the senior management team,” he says “But to be able to do that well, they need to understand their business, how it impacts the environment and how the environment impacts the business. Once you get that right, the leadership will be supportive.”
He advises EMS teams to make sure they understand the constraints and opportunities presented by environmental impacts in the context of their organisation. “If practitioners can demonstrate to the leadership how the EMS is effective in helping the organisation deal with threats and opportunities, they will be in position to have credible conversations with top management,” he argues. Baxter outlines some possible scenarios where practitioners can demonstrate how an EMS can add value. “The system could aid a finance director’s efforts to cut costs by identifying how to reduce waste, for example, or it could provide evidence of good environmental performance if that is something a major customer is demanding to see.”
Because the new standard links environmental policy and scope of the EMS to the context of the organisation it provides a good starting point for top management to engage with the management system, says Dann. “Clause four focuses on the context of the organisation and about developing a high-level understanding of the important issues that can affect, in both a positive and negative way, how it manages its environmental responsibilities,” she explains. “That should make it easier to raise awareness of the main issues among senior managers and show how the EMS can contribute to business success by highlighting opportunities and threats.”
McLaughlin at Parsons Brinckerhoff believes there is a responsibility on environment practitioners to ensure top management is compliant. “The new version of 14001 requires senior managers to do more than under the previous standard,” she says. “I expect our corporate environment and sustainability team will more frequently report to top management and they will also be involved in raising awareness of environment issues among senior managers.” She describes a fourfold approach, consisting of informing, engaging, motivating and embedding, to ensure leaders can show that they meet the requirements under 14001: 2015. McLaughlin says this is likely to consist of frequent performance alerts, regular briefing sessions and updates on how tackling environment issues can add value for each business unit. “The detail has still to be worked out, but I can envisage the development of an online briefing session for the senior team.”
McLaughlin attended the IEMA EMS forum in November and was impressed by the approach taken by the infrastructure projects division at Network Rail (NRIP) to equip senior management with environment and sustainability skills and knowledge. the environmentalist reported in December’s training supplement how the rail business is rolling out environment knowledge to its 4,000 workforce. The head of sustainable development, Tertius Beneke, explained that, for senior people in the organisation, this is all about behaviour and leadership, not technical knowledge. “They need to know what’s important, what words to use, and so on,” he said.
Roberts is another advocate of providing senior managers with relevant environmental knowledge. “One way of kick-starting leadership commitment and the transition to the new standard is for an organisation’s senior management team to sit the half-day IEMA session, ‘Leading with environmental sustainability’,” he says. He explains that the course, which was recently certified by IEMA, is based on the concept of facilitated discussion, enabling senior executives to explore sustainability at a strategic level, to review the business case and whether their company’s current strategy is fit for purpose.
The leadership clauses will be a big change for some organisations, says Norval, and many will take time to adapt. Like McLaughlin, she believes the pace at which they evolve will depend largely on environment practitioners. “I think this will require the environment team to move from being a standalone function to educating the wider business to understand environmental issues more deeply,” she says. “The environment team needs to become a leadership, training and monitoring function with the direction set at board level. This should be cyclical with reviews of progress and assessments of risk and opportunity influencing future directions, a step that is often limited in the current version to a simple review of the system itself.”
Ledwith says: “The changes should help raise the credibility of the profession, certainly for experienced, well-qualified practitioners.” She advises environment professionals to look again at the IEMA skills map to ensure they develop the skills and knowledge to communicate effectively with their organisation’s leaders and to make the most of the opportunities presented by the new standard to raise their professional position.
Norval also thinks as a result of the leadership elements of 14001: 2015 environment practitioners may need to work harder to influence the board and to maintain top management’s long-term commitment. “This will require constant effort,” she says.
Auditors’ responsibilities
How successful the revised standard is in raising commitment to the EMS at the highest levels in an organisation will also depend on the effectiveness of auditors, Edlin believes. “The audits will be critical to driving engagement. They need to see evidence that five or six members of the top management team, from the managing director to the head of HR, are all involved,” he says. “It shouldn’t be acceptable for senior management or the board to put up one representative so the others can escape their responsibilities.”
Dann is sure that 14001: 2015 will mean auditors discuss the EMS more often with senior management. She explains that the certification process at BSI requires assessors to engage with top management at least once in the assessment cycle. “This approach should become the norm now that leadership is written into the standard,” she argues. Although Dann concedes that the new, explicit requirements on leaders in 14001: 2015 might lead in some cases to difficult conversations between clients and auditors, she expects the new requirements in the revised standard to improve the audit trail and clarify where the weaknesses and opportunities to improve lie.
Baxter also emphasises how important it is for 14001 auditors to have access to senior management: “Auditors need to speak with the top management to ensure they understand the context of environment
to their organisations.”
Going further?
There is a feeling among some practitioners that the revised standard could have gone further to ensure senior management buy-in. Separating sections on environmental aspects and impacts from the sub-clause on risk associated with threats and opportunities is a mistake and could hamper leadership engagement, says Edlin. “It would have been better to embed impacts and aspects into risk. They are not separate from wider business risks,” he argues. “This is a missed opportunity to reshape 14001 as part of the risk management process, and would certainly get management attention.”
McLaughlin agrees. She describes the draft standard as weaker in this regard than the earlier drafts, which linked impacts and aspects more closely with risk. “I’ve developed an environmental risk tool for use on our projects and it would have been ideal, had the strong connection in the first draft between impacts and aspects and risk been retained,” she says.
Others caution that the new leadership requirements might be the final straw for organisations that had only regarded 14001 as a “badge”, and that these might decide to no longer use the standard or have an EMS.
Despite these concerns, most professionals see 14001: 2015 as a way to elevate environmental management from an add-on to a core business practice. Organisations have a three-year transition period after the revised standard has been published to migrate their EMS to the new edition. Meeting the new leadership clauses will be one of the major challenges to overcome on that journey.
High-level structure and top management
Both 14001: 2015 and the revised quality management standard (9001: 2015) are due to be published around the same time and both adopt the high-level structure for management system standards (MSS) approved by ISO in 2012. The aim is to harmonise MSS, so the structure, text and common terms and definitions are the same, making it easier for organisations to integrate them. The result is that the various clauses in the revised 14001 and 9001 follow the same framework, from one (scope) to 10 (improvement), with the sub-clauses reflecting the focus of the different standards. An example of identical text is: “Top management shall ensure that the responsibilities and authorities for relevant roles are assigned and communicated within the organisation.”
In its consolidated supplement setting out the high-level structure, ISO defined top management as the “person or group of people who directs and controls an organisation at the highest level”. It also referred to top management having the power to delegate authority and provide resources in the organisation. In addition, if the scope of the management system covers only part of an organisation, top management is defined as those who direct and control that part of the organisation.
