Slave to the standard

Since 1996, around 35,000 organisations worldwide have achieved certification to ISO 14001. Now the long-awaited first draft of the revised environmental management standard has been released. So, back to the drawing board? Matthias Gelber, director of environmental management systems at White Young Green Environmental, and head of the International Network for Environmental Management (INEM) delegation to the ISO Technical Committee which undertook the revision, thinks not.

International Standards Organisation (ISO) Technical Committee 207 has made available the first draft of the Under Revision ISO 14001 Standard - available in the UK through the British Standards Institute (BSI).

ISO 14001 has been successful in attracting global attention and implementation activity. Since 1996, around 35,000 organisations have achieved certification to the standard.

In some sectors, such as the automotive industry, increasing pressure exists for first tier suppliers to gain certification to the standard. Organisations such as Rover have in the past been fairly soft with the enforcement of their ISO 14001 mandate for suppliers, but it looks like the automotive companies that have put mandates out are increasingly set to enforce them.

Another major driver takes the form of the EU Integrated Pollution Prevention and Control (IPPC) directive which, whilst strictly speaking does not require a certified EMS, does strongly recommend the use of ISO 14001 and/or EMAS as a framework for managing the requirements.

Project Acorn, a DTI/BSI small business mentoring initiative, helps organisations to break the EMS requirements into bite-sized chunks and facilitates staged implementation and certification. In the pilot phase this approach has worked very well, and will, it is hoped, be available later in the year for the wider market place as a means of implementing ISO 14001 and EMAS.

Looking back at the ISO 14001 journey, I recall Thailand, where whole streets full of ISO 14001 posters illustrated the pride of the local chemical plant that had just achieved certification; a discussion on Thai TV, where a CEO was urging his fellow countrymen to embark on ISO 14001 for the good of the Thai country and the environment.

Implementation trends
I can recall doing an initial environmental review in a Russian machine factory, where metal was heated in an oven to be subsequently filled into asbestos forms that were used by the employees to 'reuse' the waste material. I can recall as well critical reports in the press when the first ISO 14001 certified companies were prosecuted by law.

Developing a standard for use by end users to communicate their respective achievements in environmental terms is always a tricky exercise. ISO 14001 was never intended to be a certificate that is only given to the best performers. The scope of TC 207 actually excludes the setting of absolute environmental performance standards - something best left to laws set by government. ISO 14001 stands for a process of continual improvement, but it does not define an absolute level of environmental performance at entry level.

International trends in the implementation of ISO 14001 include increased consideration of integrated management systems that focus on key business processes, the control of risk and the positive exploitation of opportunities. This can include quality, environment, health and safety and other management challenges and opportunities. This is partially driven by the availability of joint certification and the realisation that the 'natural way' of managing these issues within a business is not in isolation, but in a manner that aims to achieve maximum efficiency by looking at the core business processes, increasingly from a holistic perspective. The availability of joint external certification audits and ISO 19011, a guideline on Quality and or Environmental Management Systems Auditing increasingly encourages integrated audits.

The decision of how to conduct the process, however, is ultimately a question of how it best suits an organisation. In many sectors, for example, health and safety are organisationally much more closely related to environmental responsibilities than quality.

The current revision of ISO 14001 is part of the normal ISO process that requires a standard to be revisited after it has been in the market place for five years. However, in the case of ISO 14001, the revision of ISO 9001 and the publication of ISO 9001 (2000) has made the revision of ISO 14001 even more significant, and put more pressure on the process. Initially, it was envisaged that a revised version of ISO 14001 or an amendment could be published not long after the ISO 9000 (2000) standard was made available. There has been some concern at ISO headquarters in Switzerland that compatibility between the two standards should be ensured after some large international companies had emphasised this point. ISO 9000 (2000) had taken a lot of ISO 14001 approaches on board and the environmental user community argued that there appeared to be no major technical problems with joint implementation. According to one of the formal documents that map out the framework for the revision: "The revision of ISO 14001 has been focused on issues related to the compatibility of ISO 14001 with ISO 9001:2000, and clarification of the existing text to assist in unified interpretation. Any changes in the existing text should help understanding, implementation by users and environmental protection without resulting in additional or diminished requirements
in comparison to ISO 14001:1996."

New element
The big message is that there are no major changes in the pipeline that should concern current users of ISO 14001; the standard will stay more or less the same. The element structure of the standard will stay virtually the same. Only one element is likely to be taken out in the planning stage of ISO 14001, which is 4.3.4 - Environmental management programme(s). It's requirements will become part of element 4.3.3 - Objectives and targets and the reference to new or modified activities under element.

In the checking and corrective action section of the standard a new element has been included with the following wording: "4.5.2 Evaluation of legal compliance. The organisation shall establish and maintain procedure(s) for periodically evaluating compliance with applicable environmental legislation and regulations to meet the organisation's commitment to compliance." Originally, this requirement did not form part of the auditing scope (as some countries were suggesting), and came under the heading of Monitoring and measuring (4.5.1) due to American resistance. However, general consensus held that, as a critical part of the loop and a key element to the credibility of the standard, it would be better to set this requirement as a separate element in its own right.

It is interesting to note that the Committee draft only talks about the need for a procedure to be established and maintained, whereas the current ISO 14001 standard specifies a need for a documented procedure under monitoring and measuring to periodically evaluate compliance.

The remaining ISO 14001 structure is set to stay the same. Some definitions and requirements have been altered to bring them more in line with ISO 9000 (2000). This mainly relates to items in ISO 14001 that can also be found in ISO 9001, such as:

  • documentation;
  • nonconformity and preventive and corrective action;
  • records;
  • internal EMS auditing; and
  • management review.

None of these changes, however, constitute a major change to the relating requirements.

Fierce debate

One of the fiercest debates during the revision process is linked to requirement 4.3.1, Environmental aspects in the planning stage. Currently, the Standard reads Environmental aspects of its activities, products or services. European delegates supported by some other countries, in particular Argentina, requested a change to "and services" arguing that the use of "or" has given people the impression that it is optional, as opposed to mandatory, to look at activities, products and services.

Besides ISO 14001, the guidance document ISO 14004, Environmental management systems: General guidelines on principles, systems and supporting techniques, is also undergoing a revision focusing very much on bringing practical experience to the table to help with the implementation of ISO 14001. Areas such as the identification of significant environmental aspects - which has been one of the main challenges of ISO 14001 implementation - have been comprehensively covered.

Nevertheless, the revision process is far from over and there is scope for further changes to the standard and the opportunity for the submission of further comments.

The good news for users of the current version of ISO 14001 is that they will not face any major surprises when the revised version of ISO 14001 is published. Transition costs should be minimal since no new requirements have been added.

In any case, it is always best not to become a slave to the words of the Standard but to look at the bigger picture of how one can add value to the organisation and to improve environmental performance - the ultimate goal of ISO 14001. Let's not forget that while we might get caught up in the details of systems or certification requirements, common sense goes a long way in making it work well in your organisation.



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