ISO 14001
Is the Environmental Management Standard Adding Value?
Since its publication in September 1996, over 32,000 ISO 14001 (the international environmental management system standard) certificates have been issued worldwide. Although very little information is available on the number of certificates issued by the industrial sector, it is evident that an increasing number of companies in the mining and quarrying sectors are under pressure to obtain ISO 14001 certification. The drivers are varied but include supply chains and contract agreements, a leaning towards formal environmental management standards on the part of regulators, increasing awareness of the benefits of stakeholder engagement, an improved corporate image, and a genuine desire to improve environmental performance.
As most of the companies in the quarrying sector that have already gained certification have done so over the last few years, it is arguably too early to draw conclusions about the effectiveness of ISO 14001. However, the standard is already undergoing revisions based on experience to date and a number of European studies indicate that initial hopes of ISO 14001 leading to an overall raising of environmental standards have yet to be realized. The EC-funded ‘Measuring Environmental Performance in Industry’ (MEPI) project, co-ordinated by the Science Policy Research Unit (SPRU) of the University of Sussex, concluded that ‘firms and sites with a certified environmental management system [ISO 14001 or EMAS] did not appear to perform better than those without’. There has been an increasing number of companies that hold ISO 14001 certificates being prosecuted for environmental offences (ENS Report 309, pp19–22) and regulators remain wary of relaxing regulatory regimes for certified companies. Given the effort that organizations put into ISO 14001, why is it failing to deliver real environmental and business value?
There are various reasons for this but one of the key weaknesses is argued to be the approach almost universally applied to the ISO 14001 certification process, which is based on traditional quality-management system assessment techniques. This generally involves the auditor carrying out a formal document review where the organization’s EMS manual, procedures and records are assessed against the requirements of the standard. This is followed by a site walk-through during which staff are asked if they are familiar with the procedures that relate to them, and to check whether records are available and being completed properly. The output of this exercise is a non-conformities report that lists the documents that fail to comply with the requirements of the standard, based on observations made during the assessment. This approach, although very widely applied, has a number of disadvantages:
The performance-based approach focuses on the site assessment. Where an observation or finding is made, casual analysis techniques are used to determine the root cause of the issues under discussion. This involves very sensitive interviewing and detailed investigation of documentation relating to the management of the environment, including licences and permits, emissions data, drainage, site and vicinity plans etc. In order for this approach to be effective, the auditor and the site personnel have to work very closely together to gather and analyse the necessary information.
Site inspection is followed by a comparison of existing management mechanisms employed in core operations with those developed for environmental management. Environmental management should not be a bolt-on bureaucracy. Where the root cause of an observation or finding made on site indicates an underlying weakness in environmental management, the assessment aims to identify existing management mechanisms that could deliver a better environmental outcome.
With this approach, although the assessment has to ensure that the organization has the documentation specifically required by the standard, a review of the documentation is not the focus of activity. Specific documents, ie procedures, operational instructions, work instructions, records etc, are not referenced in the improvement report as fundamental weaknesses in the management of the environment unless they really are. Experience indicates that procedures are usually well written and are rarely the root cause of the issues identified.
Unlike the traditional approach to certification, the performance-based approach uses the same environmental professionals and similar assessment techniques and report formats as environmental auditing. The six-monthly or annual surveillance assessment reports not only ensure ongoing compliance with the requirements of ISO 14001, but, more importantly, provide a detailed record of changes, environmental risks and compliance issues that have occurred and how these have been addressed by site management. As it should, ISO 14001 becomes an ongoing risk-mitigation tool for site and corporate management, which can complement or be combined with corporate audit programmes and is directly relevant to the environmental due diligence process.
All organizations that apply for certification are eager to pass the certification assessment and will do what needs to be done to satisfy the certifier and to obtain the certificate. If the certifier is going to focus the certification assessment effort on reviewing documentation, then the company will respond by developing detailed documentation that will pass inspection. If, on the other hand, the certifier focuses its efforts on assessing the way the organization goes about controlling environmental risks and ensuring legal compliance on the ground, then the company will have to focus its efforts on understanding and controlling its environmental risks and ensuring that it is in compliance with the law. In terms of improvement in environmental performance, the latter is arguably much more effective in delivering tangible results.
URS Verification Ltd, Alpha Tower, 7th Floor, Suffolk Street, Queensway, Birmingham B1 1YQ; tel: (0121) 693 3785; fax: (0121) 693 3791; email: urs_verification@urscorp.com
Since its publication in September 1996, over 32,000 ISO 14001 (the international environmental management system standard) certificates have been issued worldwide. Although very little information is available on the number of certificates issued by the industrial sector, it is evident that an increasing number of companies in the mining and quarrying sectors are under pressure to obtain ISO 14001 certification. The drivers are varied but include supply chains and contract agreements, a leaning towards formal environmental management standards on the part of regulators, increasing awareness of the benefits of stakeholder engagement, an improved corporate image, and a genuine desire to improve environmental performance.
As most of the companies in the quarrying sector that have already gained certification have done so over the last few years, it is arguably too early to draw conclusions about the effectiveness of ISO 14001. However, the standard is already undergoing revisions based on experience to date and a number of European studies indicate that initial hopes of ISO 14001 leading to an overall raising of environmental standards have yet to be realized. The EC-funded ‘Measuring Environmental Performance in Industry’ (MEPI) project, co-ordinated by the Science Policy Research Unit (SPRU) of the University of Sussex, concluded that ‘firms and sites with a certified environmental management system [ISO 14001 or EMAS] did not appear to perform better than those without’. There has been an increasing number of companies that hold ISO 14001 certificates being prosecuted for environmental offences (ENS Report 309, pp19–22) and regulators remain wary of relaxing regulatory regimes for certified companies. Given the effort that organizations put into ISO 14001, why is it failing to deliver real environmental and business value?
There are various reasons for this but one of the key weaknesses is argued to be the approach almost universally applied to the ISO 14001 certification process, which is based on traditional quality-management system assessment techniques. This generally involves the auditor carrying out a formal document review where the organization’s EMS manual, procedures and records are assessed against the requirements of the standard. This is followed by a site walk-through during which staff are asked if they are familiar with the procedures that relate to them, and to check whether records are available and being completed properly. The output of this exercise is a non-conformities report that lists the documents that fail to comply with the requirements of the standard, based on observations made during the assessment. This approach, although very widely applied, has a number of disadvantages:
- By focusing on documentation, the non-conformities report tends to push the site’s environmental?professionals back into the office to rewrite documentation time that would be better spent dealing with actual environmental issues on site.
- It can lead to the development and maintenance of a ‘paper palace’ with the bulk of activity being directed at the bureaucracy of environmental management rather than, and often at the expense of, actual environmental management.
- Staff can become engulfed by paperwork, which in turn generates frustration and negativity towards the initiative.
- The EMS effort can become cyclical with short periods of intense activity during the weeks immediately preceding an assessment as the site updates and validates documentation not visited since the previous assessment.
- Managers employ a very broad range of techniques and tools to get things done, one of which is to write a formal written procedure. The assessment activity focusing mainly on documentation fails to provide the critical understanding of how things are really done and how they may need to be done differently.
The performance-based approach focuses on the site assessment. Where an observation or finding is made, casual analysis techniques are used to determine the root cause of the issues under discussion. This involves very sensitive interviewing and detailed investigation of documentation relating to the management of the environment, including licences and permits, emissions data, drainage, site and vicinity plans etc. In order for this approach to be effective, the auditor and the site personnel have to work very closely together to gather and analyse the necessary information.
Site inspection is followed by a comparison of existing management mechanisms employed in core operations with those developed for environmental management. Environmental management should not be a bolt-on bureaucracy. Where the root cause of an observation or finding made on site indicates an underlying weakness in environmental management, the assessment aims to identify existing management mechanisms that could deliver a better environmental outcome.
With this approach, although the assessment has to ensure that the organization has the documentation specifically required by the standard, a review of the documentation is not the focus of activity. Specific documents, ie procedures, operational instructions, work instructions, records etc, are not referenced in the improvement report as fundamental weaknesses in the management of the environment unless they really are. Experience indicates that procedures are usually well written and are rarely the root cause of the issues identified.
Unlike the traditional approach to certification, the performance-based approach uses the same environmental professionals and similar assessment techniques and report formats as environmental auditing. The six-monthly or annual surveillance assessment reports not only ensure ongoing compliance with the requirements of ISO 14001, but, more importantly, provide a detailed record of changes, environmental risks and compliance issues that have occurred and how these have been addressed by site management. As it should, ISO 14001 becomes an ongoing risk-mitigation tool for site and corporate management, which can complement or be combined with corporate audit programmes and is directly relevant to the environmental due diligence process.
All organizations that apply for certification are eager to pass the certification assessment and will do what needs to be done to satisfy the certifier and to obtain the certificate. If the certifier is going to focus the certification assessment effort on reviewing documentation, then the company will respond by developing detailed documentation that will pass inspection. If, on the other hand, the certifier focuses its efforts on assessing the way the organization goes about controlling environmental risks and ensuring legal compliance on the ground, then the company will have to focus its efforts on understanding and controlling its environmental risks and ensuring that it is in compliance with the law. In terms of improvement in environmental performance, the latter is arguably much more effective in delivering tangible results.
URS Verification Ltd, Alpha Tower, 7th Floor, Suffolk Street, Queensway, Birmingham B1 1YQ; tel: (0121) 693 3785; fax: (0121) 693 3791; email: urs_verification@urscorp.com
