Brian Kraus, CEO OF ERM Certification and Verification Services, calls for a new approach to implementing and certifying management systems
There is rising concern that current approaches to environmental management systems are yielding little in the way of meaningful performance improvement. This is no small concern as investment in EMS is colossal, yet underestimated.
Over 95% of the real economic cost of EMS is attributable to factors which are difficult to measure – time inputs from personnel working on programme development, auditing and especially the pre-audit blitz that precedes external audits.
Concerns about the value derived from EMS have not impacted growth in the field. Indeed there has been a significant uplift in the level of activity with the European Commission, EU Member State governments, US state and federal government agencies, and industry sector associations and others in calls to promote, or even require, the uptake of management systems and their certification.
Little or no benefit
Those who are voicing concerns about the value of EMS point to an increasing body of anecdotal and empirical evidence that shows little or no correlation between certified EMS and a variety of environmental performance metrics. These findings are surprising for many as the broad-based uptake of EMS was seen as a natural progression away from end-of-pipe thinking and most expected it to lead to significant operational efficiencies and performance gains.
Others – especially those with much experience in the field – anticipated that established approaches to EMS (structured bodies of documented policies and procedures with much training and audits to assess implementation) would yield little in the way of meaningful performance improvement, because they do not take proper account of how
organisations and their leaders actually deliver results.
Managers use a broad range of techniques, which go way beyond the implementation of policies, procedures and work instructions to deliver the operational and business outcomes they are seeking. Quality of leadership, communication of a clear vision, ability to judge character, the capacity to get the best out of people, tenacity, insight, charisma, ambition, energy, and creativity are all fundamental to an organisation’s ability to produce great outcomes.
Is it any different for environmental outcomes? Of course not. The right outcomes will arise in an organisation if – and only if – mainstream operational managers apply the techniques they naturally use in the pursuit of their operational goals to address the environmental aspects of the activities for which they are responsible.
Effective behaviours and techniques
So, can organisations (and society) get a much better return on investment from EMS? The answer is yes and, emphatically so, if implementers, auditors, trainers, consultants and very especially certifiers shift their focus from documented conformance-centred approaches to the real dynamics of performance – management and the behaviours and techniques they employ to deliver results.
This is not an academic perspective. Centring EMS on behavioural aspects and the thinking and practice that underpins them has been well tested and is producing remarkable environmental performance gains – reduced incident rates, enhanced compliance with regulations and sharp reductions in impacts on people and the environment.
For example, fifteen facilities located on three continents from two corporations with mature health and safety programmes certified to OHSAS 18001 delivered reductions of 20-30% in their lost time accident rates.
A processing plant which implemented ISO 14001 moved from near the bottom of a corporate environmental performance league table to close to the top while transforming its relationship with regulators and the community within which it operated.
And an automotive component manufacturer slashed its regulatory non-compliances by implementing ISO 14001 in a style which focuses on behavioural aspect.
Even organisations which have had certified EMS in place for a number of years have achieved significant performance gains by shifting focus onto behavioural aspects, much to the delight of senior management. “For the first time I can understand why I’m doing ISO 14001,” a senior manager of a major oil company said following a shift to a behaviour and performance-outcome focused approach to EMS.
Performance through behavioural change
Management systems and the certification of them to deliver better performance outcomes through behavioural change – is there any other way? – means all involved in the implementation and certification of EMS focusing their efforts on delivering sustainable behavioural change. The five steps set out below start with a diagnostic: before you do anything, determine what sub-optimal outcomes are arising within the operations and what their causes are in behavioural terms. You need to diagnose what is wrong with the patient before you prescribe a remedy!
Third party certification generally yields a remarkable level of management engagement and where focused on behavioural dynamics will be a source of support to those seeking to use EMS and certification to deliver meaningful performance improvements. Auditing management systems in a style which is focused on behavioural aspects in the context of certification to standards like ISO 14001 is relatively straightforward to grasp as a concept, but requires skill and practice to implement effectively.
Assessments should start with a detailed inspection where the assessors will establish if the organisation is producing the right outcomes on the ground. Experienced auditors will almost always encounter some non-compliance with regulations, examples of poor control of environmental hazards and unnecessary resource usage.
Assessors should use sophisticated causal analysis techniques to determine the management causes which have given rise to the observed sub-optimal outcomes. The content of ISO 14001 is integral to this bottom-up analysis.
Discussion with operational management will reveal the techniques they employ and the extent to which they use these techniques to drive environmental improvement. ISO 14001 should be used as a detailed agenda for this top-down discussion with management.
Throughout the assessment and especially at the closing meeting, the auditor should employ techniques to provide management with insights into the effectiveness of their actions in addressing their environmental impacts. Environmental performance outcomes are a direct reflection of the extent and effectiveness of their engagement. Management almost always gets what it deserves.
The implementation and certification of EMS is a high profile, resource-intensive initiative. For most organisations there probably isn’t a higher profile one. Unfortunately many will continue to approach EMS in the traditional way and will continue to be disappointed with the results they obtain.
Conversely, those who focus their implementation efforts on the factors which are fundamental to performance improvement by changing the behaviour of people in the organisation can achieve extraordinary performance gains for their organisations. Do we have a choice?
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