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By Kevin Munn
The chemical industry (represented by VNCI and individual companies) and relevant government ministries drew upon this guidance to formulate the Integrated Environmental Target Plan for the Chemical Industry (IETP), which details a reduction schedule for pollutants to air, water and land, as well as improvements in performance for other detrimental effects, such as noise and odour levels, the probabilistic risk from a facility/activity to the surrounding populace and the call for all companies to have an environmental management system in place by 1995.
As of 15 May 1995, 82 per cent of the companies to whom it applied had signed the DIEP. Chemical companies estimate that compliance would cost the industry between $4.8 billion and $6 billion.
The base year for measurement of performance under DIEP is usually 1985. Performance targets are set for the period 1994-95, 2000 and 2010. The 2010 targets were incorporated as guidance and are probably flexible, depending on the success in achieving the earlier targets and feasibility (in view of developments in technology, etc.). The DIEP has the force of an agreement in Dutch civil law.
A consultative group was formed to help the industry members with implementation, to monitor the progress of DIEP, and to collect data from the annual company environmental reports (CEPs); it reports this data to the Ministry of Housing, Physical Planning and Environment (VROM). It is composed of representatives from five government bureaus and from VNCI. The consultative group report is public, and contains aggregate industry data for the applicable emissions under the agreement.
In its June, 1995 report, the consultative group noted:
-- three-quarters of the companies had submitted a definitive CEP;
-- progress made in 1993-94 towards achieving the objectives of DIEP could not be reported, as only 34 per cent of the companies had submitted progress reports at that time. The group planned to report 1993-94 progress in late summer 1995. It also voiced the opinion that "the annual reporting obligation should be observed more conscientiously";
-- the group expected that the objectives for the themes of change of climate, acidification, eutrophication and waste processing would be achieved;
-- for pollutants, the DIEP goals would be achieved for two-thirds of the substances;
-- for "disruption" (noise, odours, etc.) and for soil decontamination/protection, the group could make no definite statements, owing to the "results of monitoring";
-- the group judged "that the parties who have signed DIEP have, until this moment, properly observed their obligations issuing from the declaration of intent".
Stakeholder involvement. No evidence of stakeholder involvement (outside of government and industry) was evident for the DIEP. Neither in the formation of the agreement nor in the monitoring of its implementation are NGOs or labour representatives mentioned. Corroborating this view is the recent article by FNV Industriebond,51 which details labour's input to environmental issues related to the chemical industry through works councils, yet makes no mention of DIEP.
NGO comments have generally been critical of covenants for their "non-democratic" character in comparison with conventional legislative instruments. Lucas Reijnders, of the Nature and Environment Foundation, is of the opinion that the chemical industry covenant is not ambitious enough and focuses too much on factory processes. He states, "The environmental benefits of the environmental covenant are negated by the growth in production and consumption".52 Jan Willem Biekert of the same Foundation notes, "A covenant is a contract under private law ... Therefore, the position of third parties to act via public inquiry and appeal is undermined".53
Comments. The DIEP appears to be the primary vehicle for environmental performance improvements for the Dutch chemical industry. This is due to the high enrolment in DIEP (higher than for Responsible Care in Holland). Additionally, DIEP has the appearance of being quasi-legislative; no specific measures are called for should DIEP signatories fail to satisfactorily meet the agreement's objectives, but the possibility is clearly there for the Government to take action should it feel progress is insufficient.
While DIEP is perhaps not labouring under the same level of scepticism as Responsible Care (as it was not wholly conceived and initiated by industry), it will still have to satisfy in large measure the same criteria if it is to convince all stakeholders. As such, the non-participation of NGOs and labour may affect the possibility of achieving credible results.
DIEP reported no external dialogue as a part of the process: there are no community groups where local residents learn about the companies, no national panel to contribute a balanced perspective to the consultative group, no external verification schemes and no opinion surveys to gauge public mood.
DIEP is perhaps the most developed environmental VI which the author reviewed. The inclusion of a broad range of environmental factors (outside of the normal fugitive emissions) allows for a broader perspective than pollutant-only agreements. Such a broad view (which, it should be noted, is espoused by the GPs of Responsible Care) will eventually be needed if the environmental impact of industries is to be accurately measured and true sustainable development achieved. Elements such as soil protection and operational risk assessments imply a global overview of industrial operations; the lack of progress by DIEP in assessing and reporting on these elements illustrates how much work needs to be done before such factors can be confidently quantified.
-- only sites which currently meet or exceed the requirements of the Occupational Safety and Health Administration can participate in the programme;
-- when a site is accepted into the programme, regularly scheduled OSHA inspections are replaced by annual or triennial OSHA inspections. OSHA expects each VPP worksite to act as its own "mini-OSHA" when examining safety and health conditions at that worksite;
-- as of May 1995, 109 sites were participating in VPP and represent 51 companies;
-- currently 25 unionized worksites are among those mentioned above; their business agents are required to declare in writing they are in favour of the site's participation or the site cannot participate;
-- VPP participant sites generally experience from 60 to 80 per cent fewer lost workday injuries than would be expected of an "average" site of the same size in their industries.
The results of VPP point to considerable benefit to its participants. In spite of this, the programme remains limited to a handful of sites, almost all of which are tied to large corporations. Plans for the programme's expansion were not available. Neither were details of the lessons learned, which could alert future VPP stakeholder participants as to the problems and pitfalls they might experience, and how these may have been resolved by their predecessors in the programme.
ISO has taken over the international development of standards since its inception in 1947. At present, there are over 9,600 international standards relating to a myriad of products and services. About the only fields which are not covered by ISO standards are electrical and electronic engineering, which remains the responsibility of IEC, and information technology, covered jointly by ISO and IEC. By and large, past ISO standards have dealt with technical issues, such as the pitch, depth, and tolerances of screw threads or purity requirements for different classifications of oxygen. The organization has become more involved in management systems in recent years.
The actual technical work of ISO (review and comparison of existing standards, resolution of topical details, and draft definition of the international standard) is carried out in technical committees (TCs). These may include experts from government, regulatory authorities, testing bodies, academia, consumer groups, or other organizations with relevant knowledge.
This work is highly decentralized, with over 2,700 TCs (including subcommittees and working groups) each concentrating on a specific facet of an overall standard. The major responsibility for administering a TC is accepted by one of the national standards bodies that make up the ISO membership. This member body normally appoints one or two persons to do the technical and administrative work. The committees work by consensus: as ISO standards have no legal backing, consensus is important if they are to be accepted by the parties who must comply with them. Coordination of the information flow, document publication and translation, etc., is handled through the ISO central secretariat in Geneva.
ISO's definition of consensus is different from that used in certain other organizations:
General agreement, characterized by the absence of sustained opposition to substantial issues by any important part of the concerned interests and by a process that involves seeking to take into account the views of all parties concerned and to reconcile conflicting arguments. Note: consensus does not imply unanimity.56
Standards for management systems, however, can be somewhat hard to define. The 9000 series of ISO international standards, pertaining to quality management and quality assurance, is a familiar example. The self-assessment of a business, foundation, institute, etc., can be performed internally against the ISO 9000 Standards, but the results are not as easily measurable as, say, the conformity of this page to ISO 216, which specifies paper sizes. The subjective nature of a self-evaluation opens the door to doubts on the part of external commercial partners as to the validity of the conclusions.
The solution to these uncertainties is a system of third-party certifiers of quality management (certification bodies). ISO has no formal ties with these (commercial) bodies and exercises no control over their operations, though it has issued two guides jointly with IEC: No. 40, General requirements for the acceptance of certification bodies; and No. 48, Guidelines for third-party assessment and registration of a supplier's quality system, which provide an even basis for third-party assessments. Many countries have accreditation bodies, which control the certification bodies to ensure a level of consistency and sufficient adherence to the ISO standards.
It is widely accepted that external verification by a certification body will be required for firms seeking ISO 14000-series certifications.
TC 207 is hosted by the Canadian member body, the Standards Council of Canada (SCC), in Ontario. Work is advancing quickly on the first standards, which should be published in 1996. Documents are not available for public review, but are circulated to the appropriate committee members and through them to their national constituents for comment. Liaison members will also comment on these lead documents at this point (referred to as the committee draft stage). After incorporation of these comments, a draft international standard can be issued and final changes made before the member bodies vote on its adoption as an international standard.
The six subcommittees (SCs) of TC 207 are working in the following areas:
SC1 -- environmental management systems;
SC2 -- environmental auditing;
SC3 -- environmental labeling;
SC4 -- environmental performance evaluation;
SC5 -- life cycle assessment (LCA); and
SC6 -- terms and definitions.
SC1 is concentrating on two elements of environmental management systems: systems specifications for certification or registration purposes, and management systems guidance. The former addresses core business elements which are required for standards compliance, such as executive management commitment, planning and policy development, effective implementation and operational controls, ongoing monitoring and corrective action, reviews and audits. The systems guidance expands on these core elements to provide practical help in getting started, give examples, and specifically address small and medium-sized enterprises.
SC2 is working on three primary documents:
1. general principles of environmental auditing;
2. guidelines for conducting environmental management systems audits; and
3. specifications for qualifications for environmental auditors.
These documents will consider the needs and means to ensure competence and objectivity of auditors, the use of systematic procedures, determination of audit objectives, and reliability of findings and conclusions.
SC3 is approaching the problem of environmental labelling. This issue has significant potential for commercial impact, given the level of consumer awareness and concern for environmental issues. Several national systems of environmental labelling have emerged, most notable the Blue Angel Programme in Germany and the Environmental Choice Programme in Canada. The need to harmonize the differing categories of labelling for the international consumer market has been identified as crucial.
SC4 is drafting standards in environmental performance evaluation, or the uniform measurement and evaluation of environmental management systems and environmental performance. The end result will support management's ability to evaluate the current status of its environmental management according to consistent, objective and measurable criteria. Such guidance is crucial in policy-making, in establishing performance targets, and in evaluating progress.
SC5 is concerned with life cycle assessment. Many commercial firms have been using the results of LCA to evaluate the ecological quality of their products. The results of these assessments are sometimes made public and can be used as a sort of comparative indicator in advertising. These analyses, however, have often been based on ill-adapted methodologies and data, and have created confusion in the public's mind. An international standard would allow a homogeneous comparative system to be applied.
SC6 serves a support role to TC 207 and the subcommittees, in that it defines the terms used in developing the documents of the subcommittees. It is hoped that SC6 can also develop an ISO standard of terms and definitions within the environmental field.
WG1, which also reports to TC 207, is writing guidelines for standards developers, to help them apply environmental considerations to documents in all areas of standardization. As there are literally thousands of product standards, it was sought to provide guidance on the methods for incorporating environmental factors, rather than attempting to perform this for the numerous products.
In September-October 1996 ISO issued the following standards:
ISO 14001: Environmental management systems -- Specification with guidance for use; and
ISO 14004: Environmental management systems -- General guidelines on principles, systems and supporting techniques;
ISO 14010: Guidelines for environmental auditing -- General principles;
ISO 14011: Guidelines for environmental auditing -- Audit procedures; and
ISO 14012: Guidelines for environmental auditing -- Qualification criteria for environmental auditors.
To be issued in the near future are:57
ISO 14040: Life cycle assessment -- Principles and guidelines;
ISO 14021: Self-declaration environmental claims -- Terms and definitions;
ISO 14064: Guides for inclusion of environmental aspects in product standards; and
ISO 14050: Environmental management systems vocabulary.
49 VROM, Declaration of Intent of the Implementation of Environmental Policy for the Chemical Industry 50 VROM, Consultative group for the chemical industry -- Annual report 1994, June 1995, The Hague.
51 J. van't Veld, "Works councils and the environment -- the Dutch experience", in ICEM Global, No. 2, 1996, pp. 8-9
52 R. van de Krol, Partners in grime
53 J.W. Biekert, "Environmental covenants between Government and industry -- A Dutch NGO's Experience", in Dutch environmental covenants, Vol. 4, No. 2, pp. 141-149, Blackwell Publishers, Oxford.
54 OSHA, OSHA voluntary protection programs, Internet address: http://www.osha.gov/oshprogs/vpp/overview.html .
55 K. Munn, Development of occupational safety and health management and environmental management standards: Ongoing and future work at the International Organization for Standardization, EIEET, The Hague, June 1995.
56 P. Hauselmann, ISO inside out -- ISO and environmental management, Aug. 1996, WWF, Gland, Switzerland.
57 Interview with K. Lingner at ISO, 2 Oct. 1996 and 30 Jan. 1997.
