In September 1996, the International Organization for Standardization (ISO) established a voluntary environmental management system (EMS) <EM>---- <end EM> ISO 14001. This standard is for the development and maintenance of environmental policy. In 2004, ISO-14001 was revised. Now that ISO 14001 has graduated into its first revision, this might be a good time to take a step back and look at where we have come, and what noteworthy lessons we have picked up along the way.
When the classic original version of ISO 14001 was rolled out, many pundits were quick to extol the virtues of this sibling of ISO 9001 and what it could provide to a diverse array of regulated industries. Unfortunately for the ISO standard, the reality did not immediately match the marketing hype. Many organizations took a Let's wait and see attitude. If not for the Big Three automakers, ISO 14001 might not have won acceptance. The automakers pushed its suppliers to not just implement an environmental management system (EMS) but achieve ISO 14001 certification by a mandated deadline. Electronics companies, such as IBM, and consumer giants like Sony, also played their part in drawing the line in the sand with their suppliers to achieve certification.
Interestingly, some emerging global forces, such as the European Union's directives affecting life-cycle costs of electronic equipment, e.g., 2002/95/EC, 2002/96/EC, 2003/108/EC, commonly referred to as the Restriction of the Use of Certain Hazardous Substances in Electronic and Electrical Equipment (RoHS), and Waste Electrical and Electronic Equipment (WEEE), are influencing environmental policy. Meanwhile, in the United States, the Sarbanes-Oxley Act, regulating corporate accounting practices, and public disclosure of previously confidential records, may now have a part in shaping how EMSs and ISO stimulate business policy. Time will tell.
Not a paper chase
I queried a number of company managers about ISO 14001 certification, and whether they saw a need for continued EMS assistance. As I see it, certification to ISO 14001 is just the beginning. Here's a brief summary of some of the responses I received: We passed our inspection, we don't need any help.; We have our certificate, we're all set.
To which I replied, What about your internal auditing program? Did you conduct an initial audit and go through a complete cycle including management review?
No, were we supposed to, and is lead auditor training necessary? We only generate small stuff; we're a clean facility, why do we need all this ISO stuff?
Sound familiar? In one facility, that had been recommended for certification to ISO 14001, their management received an enforcement action for violations related to secondary tank containment.
Taking this point one step further, the U.K.s Environmental Data Service (ENDS, London) conducted a survey in 2003 to identify the factors that motivated companies to seek certification. Interestingly, internal motivation is the biggest single driver, followed closely by supply chain and competitive pressure.  In reality, as we have seen from our own unscientific mini-survey, some companies view certification as their end goal and become complacent, until its time for the next registrars audit.
That view can lead to situations that may compromise the organization, and unfortunately, is shared by too many companies. Whether its to maintain the ISO 14001 or 9001 or even OHSAS 18001 certificates, maintaining the system for the sake of the sheepskin is a Pyrrhic victory of sorts. The real value to the organization is lost in translation somehow.
Let's take this argument one step further and take a closer look at a few key elements of ISO 14001:2004(E). Interestingly, those elements that were revamped were done so because too many certified organizations took the bare-bones minimal approach to develop an EMS that would pass the registrar's muster. That's why I believe the communications section was revamped, and a new clause 4.5.2 Evaluation of compliance was spun off from the original 4.5.1 Monitoring and measurement. Too many organizations, while developing and maintaining their EMS, were taking ill-advised shortcuts shortcuts that unfortunately are not one-size-fits-all. As I found out from my own experience, short cuts are no substitute for a quality product, and oversight is mandatory.
Making ISO-14001 work
So what should you look for in developing and eventually maintaining your EMS? The following is a 10-step program that may eliminate some nasty pinch points that could be dragging down the effectiveness of your EMS program:
- Design your EMS for your needs, not to satisfy an outside party. Its your system, you will use it everyday. Make sure it suits your needs, but also assure that it satisfies all elements of ISO 14001. If in doubt whether additional items fit, ask; if it makes sense to you and clarifies some function, add it in. It will probably become part of your EMS, over time, anyway.
- Choose your EMS representatives wisely. They can either make or break your system. The representatives should be people who upper management will listen to even if their message goes against the organizations norm. In addition, representatives should have latitude to disagree with upper management, should the need arise. Food for thought: one organization picked internal auditors with their own agenda. This is not only counterproductive; it also creates resistance to any potential gains that may result from the audit. Nip that potential pinch point right in the bud.
- Apply the KISS principle when crafting your procedures. Procedures that include everything but the kitchen sink may be a bit too much to handle. Can supplemental information be linked in some fashion (or hot linked) to another procedure to make the instructions more manageable?
- If you need to outsource some of the work required, do it sooner rather than later. But, as always, remember: Caveat Emptor. One organization thought it was getting a bargain with one service provider, but the system designers had limited environmental management and compliance expertise, and their system reflected that. More often than not, some companies expend greater energies in the purchase of a copier than thoroughly researching the credentials of EMS consultants.  Dont be lulled just by the lowest price bid, or a consultants claim that they can provide you soup to nuts <EM> <end EM dash> When in doubt, ask why?
- Tailor training material to your facility. Stock training materials with some cosmetic edits will pose problems later on (Step 4s recommendation applies here).
- Thoroughly research any third-party training provider. Dont forget to check their qualifications and the areas of expertise they claim to possess. As a further check, canvas the trainees to get their feel for the training provided. Be especially wary of some vendors who boast that they are qualified to perform the work you need, especially if their credentials, or websites, dont jive with their claims. Need further advice? (Go back to Step 4).
- Take ownership of the EMS components from the start. In some organizations, the end to the means is the internal audit; corrective actions are immediate and somewhat localized without looking at the big picture issues that relate to the root causes. In such cases, audits and corrective actions move in a continuous loop with no clear solution. Instead, take a grass roots approach: if workers on the floor believe in the EMS they will be more willing to support it. From another view, the more people involved, the more eyes you have looking out for your EMS. Theres strength in numbers.
- Dont isolate the EMS responsibilities, include everyone. At one organization, the EMS team had neglected to include the input of a Research & Development technician. That omission had came out during the training exercise when it was discovered that chemicals were in use which may have components in Toxic Substances Control Act Chemical Substance Inventory (TSCA). A simple tool, such as a block diagram, would have identified this chemical use. Ideally, this would have been early in the process and would have helped to avoid any unnecessary revisions to the EMS procedures (See step 3).
- Go to bat for your team when necessary. In some instances, representatives are left to flounder alone in an attempt to move the EMS forward. This is not a prudent management approach. If they need help, dont abandon them at a time when they may need your help the most. Keep your eye on your teams real goal <EM dash> <end EM dash> you seek continual improvement of your companys environmental performance the ISO parchment is just window dressing.
- Review. Go back to Step 1 to see what you may have missed, or to see what else you can try.
Having worked on EMS-related issues for quite some time, I have seen a number of issues related to management system shortfalls. I also have seen companies that were committed to continually improve their EMSs. They were truly committed to seeking areas for savings in resources and manpower, while striving to minimize waste streams, and fully empower their employees to make the important day-to-day decisions. Satisfying the registrar was more of an attaboy than the primary goal. Like Demmings quality management method, ISO-14001 is a continuous improvement plan (Figure 1). These companies understand that having an EMS at peak performance will take care of itself, and everything else will fall in line. That is the true intent of ISO 14001, not the sheepskin or the banner. We should never lose sight of that.
Figure 1. Management feedback loop is crucial for self-correcting EMS.
1. EMS survey reveals widespread concerns over certification, ENDS Report, Environmental Data Service, London, (Dec. 2003
2. Crognale, G., Practical Tips for Choosing an EMS Consultant, <ital>Pollution Engineering <end ital> (March 2002).