Ben Vivian and NQA's Max Linnemann debate the value in having an environmental management system independently certified
Max Linnemann
Sector manager for environment at certification body NQA
The starting point for this argument should be to consider an alternative world, where there is no third-party certification to standards such as ISO 14001. How can the standard carry weight if there is no formalised checking process to maintain its integrity? Third-party auditing is about one thing: assurance – and it is this assurance that adds value.
A major shift over the past 20 years has been the increased focus on reducing environmental impacts. Government can drive this change to some extent by demanding proof of improvement from its own suppliers, but how many organisations are going to provide robust evidence to publicly substantiate their claims? One has to question the value of such claims without an independent audit to verify them.
14001 is a mechanism for ensuring that any spurious claims and greenwash are minimised. It provides a credible benchmark, and businesses working against this can gain a competitive advantage. Certification encourages responsible companies by giving a tangible reward, and gives a real incentive for the poor performers to improve. It’s also worth noting that Defra endorses certification to standards approved by the UK’s accreditation body, UKAS.
There are a variety of reasons for certification: to get the badge required for a tender; because the organisation has genuine care for its impacts on the environment; or because the certificate positively affects corporate image. For the purposes of certification, however, the motive is actually irrelevant. The only thing that matters is demonstrable continual improvement.
The environment will benefit from the effective implementation of the standard, regardless of the motive, but the only way to demonstrate a company has improved its performance is to have an independent audit of the fact.
Another key advantage of third-party certification is discipline. All businesses are designed, first and foremost, to make money.
When economic conditions are strenuous, or the company is facing challenges, it is all too easy for issues that do not immediately affect business performance to slip in priority. The certification process, with its regular cycles of review and audit, ensures that this cannot happen: continual improvement has to be maintained.
Independence is an essential part of the auditing process. As an outsider, the auditor has no axe to grind and no incentive to put an unrealistically positive slant on what they find. Their role is to examine all the processes involved in meeting the standard critically and objectively.
The competence of the external auditors is a key component to ensuring value in third-party certification. Certification bodies accredited to ISO 17021 by UKAS adhere to stringent criteria that have been further enhanced in the 2011 version.
Annex B of 17021:2011 highlights the great breadth of criteria that need to be considered prior to an auditor being authorised to operate in a given industry. It is something the certification bodies and UKAS take very seriously. Competence requirements continue to rise, constantly increasing the value of third-party auditing.
Impartiality and assurance is the crux of any management standard. Without standards and their independent assessment, we risk slipping into a morass of claim and counter-claim of unproven performance that is impossible to evaluate.
Ben Vivian
Co-founder and director of the Vivian Partnership, a sustainability consultancy
At its most basic, the value gained from third-party certification is in assuring stakeholders that the policy commitments an organisation makes in its environmental management system (EMS) are being met. However, this value is inextricably linked to the quality of the audit and the capability of the auditor.
For example, to determine whether any organisation is compliant with legislation, the auditor must have extensive knowledge of the law. Frequently, I come across an environment management system that does not recognise planning or conservation laws, refers to out-of-date or irrelevant legislation, and does not adequately connect environmental aspects with relevant laws.
Many auditors don’t possess sufficient knowledge and experience of regulatory processes, so this basic value is rarely delivered. Another example is pollution prevention, a broad area which is largely determined by the organisation’s activities, products and services.
Often an EMS focuses exclusively on activities, and while auditors should require an organisation to recognise products and services if they are relevant, many allow the EMS to stand as just a facilities management or an operations management system, with no reference to commercial activities such as marketing, sales and procurement.
The fault does not lie solely with the certification bodies, as organisations can define the scope for their EMS too narrowly, or fail to engage their commercial functions in the system because it’s “too difficult”.
The environmental impact of manufacturing a product is often a remarkably small part of the total impact when raw materials, use and disposal are also considered.
An EMS must address this, and it is down to third-party auditors to highlight this issue when they discover that a company’s focus is only on the operational side of their environmental performance.
The final area of value that should be gained from a certified EMS is the demonstration of continual improvement. Why go through the process if, at the end, there is no change?
However, in reality many management systems contain weak statements of aspiration that are impossible to audit. Too many auditors accept promises of improvement, and when none is delivered seem to shrug their shoulders and allow the practice to continue.
Perhaps the biggest concern for third-party certification is the growth of unaccredited certification. Companies asked by customers to achieve 14001 can now buy an off-the-shelf environment management system and certification, the ultimate box-ticking and valueless exercise.
The solution to ensuring value from certifying an EMS is not simple and involves all the parties. While it is easy to point an accusatory finger at the certification bodies, organisations with environment management systems need to review their commitments to make sure they are getting the most out of certification.
Meanwhile, certification bodies and UKAS need to review the evaluation of auditor competence – mere sector experience is not enough; there must be some recognition of understanding of the commercial elements involved. Updating their knowledge of legislation should be a basic part of the continuing professional development of 14001 auditors.
Auditors must be capable and supported for true value to exist in third-party certification; then the process will be worth it.
