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By Kevin Munn
A survey by the management consultancy Arthur D. Little in 1995 of 115 US and Canadian companies revealed that 60 per cent of them felt that third-party certification of their EMS to ISO 14001 was important to the future success of their company; 65 per cent felt it likely that their firm would seek ISO 14001 certification in the near future.62 Clearly, many firms are taking the standards seriously.
Amidst all the hype for ISO 14000, there are those who are asking "Is ISO 14000 really a good thing?", "Will it help the environment?", "If I have an EMS, what do I have to do to have an ISO 14000 certification?" Let's look at these one at a time.
"Is ISO 14000 really a good thing?" Page 1 of ISO Membership63 states: "ISO's mission is to promote the development of standardization and related activities in the world with a view to facilitating the international exchange of goods and services and to developing cooperation in the spheres of intellectual, scientific, technological, and economic activity".
Considering that ISO 14000 will most certainly ease certain barriers to international commerce it can be argued that it effectively aids ISO in fulfilling its stated mission. Twenty-eight per cent of surveyed companies saw a potential competitive advantage in certain markets coming from an ISO 14001 certification.64
As with many global developments, not every concerned stakeholder stands to benefit. This study notes many dissenting opinions on the current methods used to measure environmental performance, and ISO 14000 has its critics as well. Take for example the impact of the standards on developed versus developing nations. Developing nations see the potential for ISO 14000 to become a trade barrier to their goods in a global market: eco-labeling schemes in developed countries can pose barriers to imports; market demands for ISO 14000 certification could pose strains on local enterprises.65
Consider that the ISO 14000 standards will not require, in the case of more environmentally progressive companies, a major overhaul of their current management practices (see below). In developing nations, however, a culture built on a history of rigorous environmental legislation and scrutiny typically does not exist. Businesses in developed nations, then, could suddenly find themselves with a de facto trade advantage. ISO has a developing country committee, and its chairman has in fact recommended that developing nations voice their concerns within TC207.66
Many other concerns exist for individual actors, and as ISO 14000 standards come into greater use the issues will spark further discussions. But overall opinions are generally favourable. Also, globally, any development which will bring about a greater awareness of environmental issues could be viewed as positive.
"Will ISO 14000 standards help the environment?" ISO 14000 standards are concerned with EMSs. This is different from environmental performance. When a firm complies with the standards and achieves a certification status, this is not any guarantee that their environmental performance will benefit, or that they even have laudable environmental performance in the first place. As one recent guide to the standards notes, the "process can equally enshrine mediocre or ambitious environmental performance objectives ... and still satisfy certification requirements".67 As a standard, ISO 14001 will attest that a particular EMS can assess, manage and monitor the environmental elements related to a firm's operations.
The line of thought here is that, if a firm scrutinizes its management of the environmental aspects of its operations, it will become more aware of the environmental impacts of its operations, and can work towards improvements. This logic was borne out with the adoption of the ISO 9000 series for quality management: many firms reported improvements simply because the assessments which were necessary to obtain ISO 9000 certification made them aware of shortcomings in their operations.
But ISO 14000 standards have no requirements as to, for example, levels of pollutants emitted. They require companies to meet local and national regulations, but these (and their enforcement) vary widely. Without an environmental reporting requirement or a commitment to continuous improvement, then, a firm's environmental performance need only be as good as the regulatory system which oversees it. This could explain the "healthy scepticism" towards ISO 14000 in the environmental community, as observed by W. Ross Stevens, Manager of Corporate Issues at DuPont and part of the ISO group on environmental performance evaluation standards. Denis Boyle, ESH Director for Arco Chemical sums it up well, "If people were to do this for the sake of window dressing, then it's not going to be worth much. But the conceptual approach is sound in terms of defining the management systems".68
The current version of ISO 14000 is weaker with respect to performance than earlier drafts. Reports Joel Charm, Director of Health, Safety and Environment Sciences for Allied Signal and Chairman of the US delegation to an ISO subcommittee developing ISO 14000 standards, "The subject of continual improvement has been [one] of great debate in the ISO 14000 process". He refers to the idea of "continual improvement in the management system that would lead to improvement in environmental performance". This is not what the Europeans, particularly the Germans, had in mind. They "want to see continual improvement in environmental performance as the key focus".69 The concept on continual improvement is incorporated in some other EMS standards, and this is discussed below.
While there are no guarantees that the global environment will improve as a result of the widespread adoption of ISO 14000 standards, it is reasonable to expect that improvements will materialize. Naturally, the will of a firm to improve its environmental performance is the key issue here. An EMS certified under ISO 14000 is a tool which need not encompass the complete means and commitment for achieving improved performance.
"If I have an EMS, what do I have to do to have an ISO 14000 certification?" According to one chemical company manager, companies with strong EMSs in place may find ISO 14000 a "no-brainer", with certification being a walk-through exercise of ISO 14000 elements "that any competent environmental manager would have in a programme."70 While this assessment may prove correct for more (environmentally) advanced businesses, the process of self-evaluation and certification will still require a considerable effort. Many firms will undoubtedly be required to alter/improve their operations or management practices to achieve compliance.
Such efforts do not come free. Bayer estimated its costs for achieving EMAS compliance at its Dormagen site at DM2.6 million for the two-year initiation period and DM233,000 annually to continue the programme.71 The financial barriers, especially to small and medium-sized enterprises, are obvious.
ISO 14000 and EMSs Three international standards are reviewed here, the others being BS 7750 and EMAS. ISO 14000 is the weakest in calling for systems and corporate commitment which will bring about environmental improvements. As described by Charm, "ISO 14001 is not the be-all and end-all of management systems standards. There are many other aspects to having an effective management system than simply the core requirements of ISO 14001. But these core requirements are recognized by all countries as the minimum that would be acceptable on a global basis." Frank Friedman, EHS senior Vice-President for Elf Atochem North America, expresses a somewhat more critical view: "There is a value in international standards, if they raise all boats. But the environmental community has some doubts on that (with respect to ISO 14000), and frankly I do also ... We are already developing systems that go well beyond ISO 14000."72
EMAS and BS 7750 are other EMSs which have gained international recognition and use. BS 7750 was essentially the predecessor of ISO 14000, the blueprint from which the ISO standards took their initial cues.73 EMAS, which also grew out of BS 7750, is detailed in the EC Directive of 29 June 1993 on the voluntary participation of companies from the industrial sector in a community environmental management and environmental audit system. The European Committee for Standardisation (CEN) has published a guide relating EMAS and ISO 14001.
Whatever the order of appearance, all three have evolved through a process of involved debate and discussion, and they have their individual qualities. From the documents reviewed, it appears that generally speaking EMAS and BS 7750 are similar in their requirements. ISO 14001 contains the essential management system practices of the other two, but notably does not demand their level of reporting requirements or stakeholder interaction. BS 7750 requires that a corporate environmental policy go beyond legislative compliance, and seeks continuous improvement in environmental performance, which must be communicated to interested parties in a clear manner.74
As to certification, BS 7750 stipulates that an internal and external audit be carried out every three years (every year for organizations with a high potential for environmental impact). EMAS also requires external verification. ISO 14001 does not require external verification, but the general consensus is that certification will be a de facto requirement in the near future.
As an indication, VROM in the Netherlands explains in its guidance to government authorities and companies75 that companies which comply with BS 7750 automatically comply with EMAS. One caveat they add is that EMAS also requires the publication of a corporate environmental report (CEP). VROM reserves judgement on the ISO 14001 standard for the time being, as this was still under development at the time the guidance was published.
Some of the ISO 14000 series of standards apply to issues which do not appear to be addressed in EMAS or BS 7750, such as life cycle analysis, environmental labelling and accreditation of auditors. This last issue is of course crucial, and may explain the popularity of ISO 14000 standards; the ISO has issued requirements for certification bodies in conjunction with the EMS standard.
Yet other companies are satisfied with the level of ISO 14000, preferring them to the other EMS standards. Solvay France's Industrial Relations Manager Claude Lanci has criticized EMAS as bureaucratic and having too rigid a communication policy. He prefers ISO 14001.76
Many stakeholders, however, prefer the more rigorous requirements of EMAS. WWF reiterates the key additional requirements of EMAS over ISO 14001:77
-- an environmental policy that provides for compliance with relevant regulation, has a view to reducing the environmental impacts to levels not exceeding those corresponding to best available technology and is publicly available;
-- a preliminary environmental review; and
-- an environmental statement which shall be designed for the public and written in a concise, comprehensible form. This statement shall include, inter alia, a description of the company's activities, as assessment of all relevant environmental issues, a summary of the data on emission of pollutants, waste generation, energy consumption, etc., the company's environmental policy and management system.
And, as detailed above, the Dutch Ministry of the Environment further notes the requirement under EMAS for verification by an authorized and independent entity.78
These missing elements of ISO 14000 are exactly those which have been identified as both problematic and key to the credibility of the Responsible Care programme. Will these prove a hindrance to the adoption of ISO 14000? Most probably not. The business community has already embraced ISO 14000 standards, and the accreditation process provides the assurance that a suitable EMS exists. But what about companies who would like to deal with partners who are truly committed to high standards of environmental performance? ISO 14000 certification alone does not seem to guarantee this, nor offer any means for distinction between firms with different levels of performance. This same argument holds for non-commercial stakeholders. What confidence can an environmentally-conscious consumer put in ISO 14000 certification vis-à-vis a company's products?
The most notable differences between ISO 14000 and EMAS/BS 7750 are the former's lack of reporting requirements or public disclosure. One hurdle the ISO standards faced in the negotiating phase centred exactly on this subject. US companies argued that the standards should not recommend the disclosure of the results of environmental audits to assess the effectiveness of their EMS. They feared that such disclosure could be used against them within the more aggressive US legal and regulatory system.79 It appears that the US concerns were largely adopted in the final ISO 14001 text. It remains to be seen whether stakeholders external to the industry will take issue with the less proactive requirements of ISO 14001, and whether public opinion can be both informed enough and vocal enough to affect corporate decisions over which EMS standard to adopt.
EMSs and Responsible Care A number of national associations have detailed the differences between their Responsible Care programmes and one or more of the various EMS standards. These are summarized below.
United States
CMA has prepared a matrix which serves as guidance for members wishing to identify the additional requirements for ISO 14001, given a Responsible Care programme which meets the criteria of the CMA management systems verification protocol. CMA describes these three significant areas for additional development.80
1. Documentation. ISO 14001 provides for evaluation of documentation that describes the requirements of the EMS, the process for document control and revision. The Responsible Care MSV protocol, by design, is not as prescriptive about documentation. The MSV only asks for documented procedures to ensure safe operations.
2. Record keeping. ISO 14001 has very detailed requirements for procedures related to identification, maintenance, disposition, legibility, storage, retrievability, protection and retention time of records. The MSV protocol references the maintenance of sufficient data files to enable analysis of trends, but it does not specify records requirements.
3. Legal compliance. A section in ISO 14001 addresses procedures and responsibilities for handling non-conformance. This is not specifically addressed in the MSV protocol, but is covered in a more general manner in the protocol's section on implementation, operation and accountability. However, a formalized procedure for corrective action is not specified in the MSV protocol.
Canada
CCPA's guidance document relates ISO 14001 and the Canadian Responsible Care programme. It makes the following observations:81
1. ISO 14001 covers about 20 per cent of the 152 code elements of Responsible Care, but does not address:
-- employee health and safety;
-- community involvement;
-- product stewardship;
-- second-party assessments;
-- new product development;
-- transportation;
-- former sites;
-- proactivity in public policy development.
2. The Responsible Care GPs, policies, codes and programmes cover and exceed, in intent, all the elements of ISO 14001.
3. Responsible Care codes are prescriptive enough to meet registration requirements for only 25 per cent of the elements of ISO 14001. The shortcomings are in:
-- elements of an environmental policy;
-- environmental training;
-- inventorying environmental aspects of operations;
-- document control procedures;
-- management roles and responsibilities;
-- need for setting environmental targets.
4. Responsible Care is a much more subjective evaluation.
CCPA further observed:
1. ISO 14001 has the potential to provide added value to CCPA member companies above what they might choose to do for compliance with Phase I of Responsible Care.
2. CCPA will evaluate ways to gain recognition of Responsible Care's more comprehensive coverage compared to ISO 14001. Companies should recognize, however, that market dynamics may still ultimately require them to register under ISO 14001.
Australia
PACIA formed a Responsible Care/ISO 9000 working group due to the many requests from members for assistance in implementing their Responsible Care programmes. The results are a matrix cross-referencing the various Responsible Care elements with the ISO 9000 standard requirements.82 The working group will further work with companies by providing case-studies from the more advanced members as examples to those who are still developing their Responsible Care programmes.
UK
CIA refers to its publication "Responsible care management systems for health, safety and environment" as an interpretive guide written in such a way as to address the requirements of the ISO 9000 Series, BS 7750, EMAS, ISO 14001 and the Health and Safety Executive's publication "Successful health and safety management" (HS(G) 65).83 The document was not available for review.
CEFIC
Kemikontoret of Sweden refers to a CEFIC document in preparation which will provide guidance for relating ISO 14001, EMAS and Responsible Care. No current documents were found on this subject.
Netherlands
VNCI has put together a document linking the elements of Responsible Care with BS 7750 and ISO 14000 standards. Details were not given.
1. What are the likely benefits of voluntary standardization at the international level of OSH management systems?
2. What are the possible disadvantages resulting from voluntary standardization of OSH MS?
3. Is there a need for ISO to start work in this field?
The workshop took place with the knowledge that a number of standards bodies were already carrying out ground-breaking work on OSH MS standardization. The British Standards Institution (BSI) was working on it and had published guidelines, rather than a standard, insisting that these guidelines should not be used for certification purposes. Standards Australia (SAA) had published an OSH MS standard for the construction industry and was in the process of completing a generic OSH MS standard. Denmark was also interested and was working on the preparation of an OSH MS standard, whereas Norway preferred the inclusion of OSH requirements into a general management system, that also integrated quality and environment.84
The conclusions of the workshop provided the guidance for ISO in determining whether or not to initiate OSH MS standards development.85 Specifically:
-- employers/industry do not expect that there would be improvement of OSH from an ISO standard and see a risk of misuse related to certification practices. This group also expressed concerns for the costs of implementing such a standard, and questioned the benefits to be gained from it;
-- labour representatives believe they are not well-represented in ISO. They also stated that ILO is looking after their needs well and that the tripartite system works. They believe that OSH MS are more appropriately addressed at the local or regional level.
The workshop recommended that ISO should not undertake development of OSH MS at the present time. A questionnaire was distributed at the workshop to all participants, in order to ensure that everyone interested had a chance to provide input. The draft proceedings of the workshop have been mailed to all participants and they were asked to provide their comments via the ISO member body for their country, to ensure coordination.
At its 27-28 January 1997 meeting, the ISO Technical Management Board confirmed that ISO would not start work on OSH MS standards development. The Board noted:86
that the outcome from the international workshop on OSH MS indicated that there was little support from the main stakeholders for ISO to develop international standards in the field of OSH MS. [Furthermore] considering that a need for the development of such standards may arise in the future, but does not exist at the present time, [the Board] invites ISO member bodies to report to the ISO central secretariat on the development of standards in this field at the national and regional level for subsequent publication of the information in ISO bulletins, [and] decides that no further action should be taken at this time to initiate activity within ISO in the field of OSH MS standards.
58 T. Tibor, with I. Feldman, ISO 14000 A guide to the new environmental management standards, 1995, Irwin Professional Publishing.
59 Interview with K. Lingner at ISO, 2 Oct. 1996 and 30 Jan. 1997.
60 Z. Mansdorf, "The ISO man cometh: Moving to global standards", in Occupational hazards, May 1995, pp. 43-36
61 M.B. Powers, Companies await ISO 14000 as primer for global eco-citizenship
62 L. Boulton, "Vote on `green passport'", in Financial Times
63 P. Hauselmann, ISO inside out -- ISO and environmental management
64 L. Boulton, "Vote on `green passport'", in Financial Times
65 ISO, The ISO 14000 environment
66 op. cit.
67 A.M. Thayer, Chemical companies take wait-and-see stance toward ISO 14000 standards, C&EN, 1 Apr. 1996, pp.11-15.
68 op. cit.
69 op. cit.
70 op. cit.
71 "EMAS and all that jazz", in Chemical Matters, issue 314-315, pp. 6-8.
72 A.M. Thayer, Chemical companies take wait-and-see stance toward ISO 14000 standards, C&EN, 1 Apr. 1996, pp.11-15.
73 VROM, Company environmental management as a basis for a different relationship between companies and governmental authorities: A guide for governmental authorities and companies
74 op. cit.
75 op. cit.
76 EMAS criticized by Solvay France", in European Chemical News (ECN), 25 Sep.-1 Oct. 1995.
77 P. Hauselmann, ISO inside out -- ISO and environmental management
78 VROM, Company environmental management as a basis for a different relationship between companies and governmental authorities: A guide for governmental authorities and companies
79 L. Boulton, "Vote on `green passport'", in Financial Times
80 CMA, CMA Responsible Care management systems verification information kit
81 CCPA, A primer on Responsible Care and ISO 14001
82 PACIA, Guidelines for Responsible Care integration with the ISO 9000 quality standard
83 S. Aaron, Responsible Care and integrated management systems
84 ISO, Occupational health and safety: An ISO contribution?
85 ISO, Unconfirmed report of the ISO International Workshop on Occupational Health and Safety Management Systems Standardization
86 ISO, phone conversations with ISO, 30 Jan. 1997.
