EMS from above?
The root causes of an inadequate Environmental Management System (EMS) and the associated failures under audit conditions by a certification body can often be traced back to the management decision-making that initiated the EMS programme in the first place. David Clark, ETaC, follows the trail.Why did the management team decide to institute this system for environmental protection? Was it an attempt to change the culture within the company in order to create a more favourable climate for responsible environmental practices, or, as is sometimes the case, was it a reactive response to a major customer's demand?
In recent years it has become increasingly common for purchasing departments to 'hijack' the need for an EMS in order to exercise commercial blackmail over their long-suffering suppliers. Through the application of the 'continual improvement' philosophy of ISO 14001:1996, it was hoped that the insidious spiral of supply-chain pressure that had built up around the requirements for Quality Management Systems based upon ISO 9001/2 in the early 1990s would be avoided. Unfortunately, thanks to the smooth-talking purchasing manager ("let me give you our interpretation of ISO 14001 that will ensure that you supply us with cheaper widgets, as well as saving the planet"), implementing an EMS has become just another certificate-gathering objective for hard-pressed manufacturing managers. Such a view may appear cynical, but is the inescapable conclusion that is reached when senior managers claim, in ever-increasing numbers, that they are 'required' to gain certification to ISO 14001 in order to protect their markets.
In reality, an environmental management programme focused on continual improvement, agreed and implemented by customer and supplier in co-operation, has been shown to lead to more effective measures for protecting the earth's finite reserves, reducing pollution and waste, as well as providing economic benefit to both parties. The energy saving, waste minimisation and environmental risk reduction measures required by such an approach are analogous to the Total Quality tools that also benefit company performance. However, such benefits may not be seen when the primary reason for the implementation of an EMS is the result of demands in the supply-chain. Such initiatives would be far more readily adopted as the basis for mutual development by supplier and customer than where the supplier is being "told" to implement in order to "protect" supplies of product that have already satisfied customer requirements for some time.
This is only one example of a typical situation that may create a lack of management commitment, and that which is often found to be at the root of many audit failures against the requirements of ISO 14001. Subsequently, it is not surprising to find that the despairing supplier's management succumb to this induced pressure by instructing one of their own overworked middle-managers to take on the additional EMS responsibility. The latter unfortunate is effectively handcuffed and de-motivated before a start can even be made.
The ISO standard requires "management commitment" to three fundamental principles:
These will only become the basis of company practice if senior, "executive" management ("top management" as defined by the Standard) is actually seen to accept them and subscribe to them in everything that they do. Delegation alone is not effective; taking responsibility for one's surroundings and conditions requires encouragement and reassurance that it is not being done in isolation. Working together as a team that shares the same ideals and objectives is more likely to encourage and inspire than simply being told what is necessary. Respect for, and the sharing of, principles concerned with environmental responsibility only result if those charged with leadership accept that role and demonstrate that they believe in the necessity of environmental probity for their company themselves.
Introducing strategies to meet the requirements of ISO 14001 is an effective way of shifting the culture towards personal environmental responsibility in a company, as well as a means of increasing efficiency. In clause 4.4.2 (training, awareness and competence) of ISO 14001, the organisation is required "to establish and maintain procedures to make its employees at each relevant function and level aware of the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance". (Reference has already been made to environmental management needing a culture change in organisations and it is in this clause that this fundamental change in approach is articulated.)
Policy statements can provide the basis for environmental improvement, but the reality is that only when individuals accept responsibility for their part of the system at their own work-place, continuously, will that evidence of environmental improvement be readily apparent. Achievement of a change of this nature by all employees could reflect a profound cultural shift for many companies, but is unlikely to happen at all unless top management demonstrates belief in its importance.
It is interesting to note the introduction of a similar requirement in the new Quality Standard, ISO 9001:2000. It requires that "top management shall provide evidence of its commitment to the development and improvement of the quality management system", whereas earlier versions only required that "management with executive responsibility shall define and document its policy for quality, including objectives for quality and its commitment to quality". Commitment needs to be perceived and respected from the top down if the difficult and painstaking ongoing diligence necessary for the consideration and management of environmental issues is to be effective within the organisation.
From the outset, it needs to be recognised that it is unlikely that all of those who comprise "top management" will automatically be convinced of the merits of environmental protection and pollution prevention within their own company. An often-heard rejoinder is that "our company does not have an effect on the environment". A willingness to be prepared to attend an awareness raising seminar or workshop, presented either by a respected and/or authoritative member of the organisation, or a recognised and capable training organisation, is the very least that must be expected of all the management team. How can one's prejudices or ignorance be influenced unless the opportunity is taken to try to understand how and why the care of the planet depends on our actions every day of our lives? Realising and, hopefully, accepting that we all have to play our part, is the beginning of commitment.
Sadly, certification body auditors recount that it is often at more senior levels in some organisations that a realistic appreciation of environmental impacts resulting from their activities is lacking. Consequently, the opportunity is missed again and again to improve efficiency, as well as the perception of the business. Where managers have taken time to consider how their activities and processes affect the environment, they are often surprised both by what they are causing and, more importantly, how relatively straightforward is the opportunity to reduce their consequences. Understanding the approach that is embodied in the Standard can also be surprisingly straightforward. Commitment is required to pollution prevention and continual improvement, in addition to compliance with the relevant environmental legislation of course, that is "appropriate to the nature, scale and environmental impacts" of the organisation. There are no artificial absolutes; no specific environmental performance criteria. Commitment, however, is required. The Standard requires that management simply assess objectively what their impacts are, prioritise them according to their own evaluation of each respective risk to the environment, and then control or improve them progressively according to the resources of that organisation.
ISO 14001 does not expect companies to spend vast sums of money on technical equipment and sophisticated monitoring devices. Many environmental control methods are cheap to implement and easy to understand. For example, waste segregation can be achieved by providing different coloured waste bins and labels telling people which waste goes where; reduction of water discharge pollution can be achieved by simply colour-coding drains and letting staff know what can be poured down which drain.
Provision of resources, another of the key principles of the Standard - specifically, time for key personnel to implement the EMS and also for training the workforce - only happens grudgingly in such situations where commitment from the top is lacking. In this situation the person(s) charged with implementation and management of the EMS will find it impossible to gain support, commitment from others and even respect for the task.
Whenever "top management" actively support clause 4.3.1 (Environmental aspects) by identifying "environmental aspects of (the organisation's) activities, products and services that it can control and over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment", it is usually readily apparent to external system auditors. A consensus is achieved on the scale of the environmental risks to the business (the significant aspects), which results in commitment to the improvement programme and the provision of appropriate resources. Recognition of environmental requirements is now part of the overall management strategy of the company.
Commitment to the programme by top management results in a more definite and positive review of the effectiveness of the EMS (as required by clause 4.6 of ISO 14001). Accountability for the environmental programme targets is then more easily demanded and monitored, since there is a better appreciation of both the need and the costs of what has been undertaken. This will cascade down the organisation and encourage a more positive response by everyone - not because this is just another management wheeze but, rather more critically, because the organisation is now working with others, to the best of its ability, to ensure the future health of this planet and its inhabitants.
Recognition by the regulators that EMS implementation indicates a more responsible attitude on behalf of senior managers is beginning to take place. Very soon customers, consumers, neighbours and the general public will be rewarding the enlightened organisations which are joining the ever increasing list of the environmentally responsible companies who are successfully managing their environmental issues.