In theory, the development of Environmental Management Systems (EMS) is a fantastic way to reduce a company’s impact on the environment. If an EMS is designed and maintained effectively it can provide a perfect platform to implement an organisation’s sustainability strategy. Unfortunately the bureaucratic and box ticking approaches that are traditionally used to do this are outdated and put simply – do not work.
An effective EMS engages staff, facilitates systematic improvements in environmental performance and allows an organisation to credibly communicate that it has an approach in place to mitigate its impacts. The ISO 14001 standard was developed to support organisations in implementing effective systems. However, most environmental management professionals would agree that (for various reasons) it hasn’t managed to optimally facilitate this.
Picture this situation: An organisation has been asked by its customers or a parent company to implement an EMS in order to achieve certification to ISO 14001. The Environmental Manager develops a ‘system’ which consists of a range of documented procedures to meet the requirements of the standard. In addition to this, he or she maintains a number of spreadsheets on his or her computer to record environmental metrics and document legal requirements. An auditor from an accredited body visits the organisation and confirms that the company meets all the requirements of the standard and the company achieves third party certification. The company celebrates it’s achievement of having reached the ‘pinnacle of environmental management’. A year goes by and the auditor is back – again the company achieves certification (perhaps with a few corrective actions). While the company celebrates that the sales team can inform its customers that the organisation has achieved certification – the Environmental Manager knows that in reality few of the staff members read the ‘folder on the shelf’ system and that environmental management and sustainability principles are far from integrated into the business.
Does this scenario sound familiar? You may have a system like this in your own company. If you are a management systems consultant or auditor you will almost certainly have developed or audited ‘systems’ like this for your clients. The implementation of management systems using this approach is very common in New Zealand and around the world. It is not unusual that ‘folder on the shelf’ systems lead to a lack of awareness and commitment by management and employees.
This situation has led to the perception that there is limited value in implementing a traditional EMS as described above. Not surprisingly there has been a lack of uptake of EMS and ISO 14001 certification in New Zealand. At the time of writing only 286 certificates had been issued in this country (according to the JAS-ANZ website).
The ISO 14001 standard is currently being reviewed by a technical committee of the International Standards Organization. This will come as a relief to some and a burden to others. The changes involve amendments to the structure andrequirements of the standard.
The structure of ISO 14001 will be amended to incorporate a ‘high-level structure for management systems’ to facilitate the alignment and compatibility of the EMS standard with other management system standards such as occupational health and safety (OHSAS 18001) and quality (ISO 9001). This is an important step as organisations are rightly looking to integrate their management systems to increase their efficiency and move towards sustainability management.
The changes proposed to the requirements in the draft version of the ISO 14001 standard are more fundamental. The most significant changes to the requirements in comparison to the 2004 version of the standard are as follows:
There is an increased focus on the actual environmental performance of the organisation. In the past, companies have come under scrutiny (for reasons made obvious in this column) for having a ‘system’ without actually reducing their environmental impact. The current draft requires the continual improvement of the environmental performance of the organisation whereas in the 2004 version the focus is on the continual improvement of the system. The increased focused on environmental performance is absolutely key as this is of course the primary reason why organisations should be implementing an EMS.
The needs and requirements of interested parties will require greater consideration in the development and maintenance of an EMS. The increased emphasis on considering the views of internal and external stakeholders will align ISO 14001 with reporting guidelines such as the Global Reporting Initiative (GRI) framework. This is fantastic because all too often there seems to be a disconnect between the operational performance of organisations (in terms of their EMS) and their external environmental communications.
Upstream and downstream activities in the value chain that are considered to include significant environmental aspects will need to be taken into account in the design and operation of the EMS. This is perhaps the most significant change proposed in the standard as it will require organisations wishing to gain certification to consider the entire life cycle rather than just their own operations in the scope of their system. By including upstream and downstream activities in the design of an EMS, organisations will ensure that they are not inadvertently shifting environmental burdens to other stages of a product or service life cycle.
I am hopeful that the proposed changes will go some way in mitigating the compliance and box-ticking approaches which are currently prevalent.
The proposed changes to ISO 14001 have not been confirmed and are two years away from being enacted. A window exists for organisations to be proactive and improve their system to make the transition to the revised standard smoother. There are real and tangible business benefits of moving beyond the compliance focus and adopting a performance based approach to environmental management and sustainability.