Slave to the standard

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.