Business Management for a Sustainable Environment
Unit 3 Environmental Management Systems
15-May-08
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Contents
Introduction ........................................................................................ 5 Learning outcomes ............................................................................ 6 Why do we need environmental management systems? ................. 7 Adaptive management and EMSs ..................................................... 8 EMS standards.................................................................................. 11 ISO 14000 series of standards ......................................................... 11 The nature of ISO 14001 .................................................................. 16 Principles underpinning ISO 14001 ................................................ 16 What is the aim of ISO 14001 and the 14000 series? ..................... 17 ISO 14000 series and trade.............................................................. 18 Relations between ISO 14001 and other management systems ...... 19 Elements of ISO 14001 ..................................................................... 20 Initial environmental review ........................................................... 21 Environmental policy ...................................................................... 22 Planning........................................................................................... 26 Implementation and operation......................................................... 29 Checking and corrective action ....................................................... 33 Management review process ........................................................... 35 Certification or self-declaration ...................................................... 36 Uptake of ISO 14001......................................................................... 37 Barriers and drivers to uptake of EMSs .......................................... 38 Will ISO 14001 lead to lower impacts on the environment? ........ 44 And what about sustainable development? ..................................... 44 Conclusion ......................................................................................... 47 References and further reading....................................................... 48 Readings ............................................................................................ 51
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Introduction
In Unit 1, we provided a background to the emerging concern regarding the impact of human activities on the environment over the past 40 years – the emergence of modern environmentalism – and the institutionalisation of that concern by governments through legislation, policy and development of managing environmental agencies. In Unit 2, we discussed the development of the concept of sustainability through the 1980s and its adoption into worldwide policy and legislation, particularly following the 1992 Earth Summit in Rio de Janeiro. That summit – importantly – involved the business community, particularly through the Business Council for Sustainable Development, in focusing on the role of business in the move towards sustainability. This role has continued to grow in the past decade, especially in the past few years. Corporate social responsibility (CSR) and reporting on environmental/sustainability performance have now become an important part of overall management for many sectors and individual organisations. As well, the past couple of years has brought a wider range of sectors into this arena – importantly, including banks and financial institutions. This Unit is about how businesses and other organisations can take a systematic approach to analysing their impacts on the environment, about setting in place goals for reducing these impacts, and processes to achieve these goals within a cycle of continual improvement. In other words, it is about Environmental Management Systems (EMS). The 1992 Earth Summit not only gave a boost to interest in sustainability and the setting in place of policies by organisations aimed at sustainability outcomes, but it also acted as the trigger for development of environmental management standards for business and industry. The purpose of this Unit is to discuss the role of EMSs for organisations; in fact, the EMS may be viewed as an organising framework for this course as a whole. An EMS is concerned with ensuring that an organisation takes a systematic approach to “the evaluation of how its activities, products and services interact with the environment and to control those activities to ensure that established environmental objectives and targets are met” (Hortensius & Barthel 1997, p. 23).
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An EMS may simply be a self-designed process put in place by an organisation and self-monitored and assessed. On the other hand, it can be a highly formal process that follows one of the documented structured schemes put in place during the 1990s that may result in certification by a third party. These include ISO 14001; the British Standard, BS 7750 (now obsolete); or Europe’s Eco-Management and Audit Scheme Regulation (EMAS).
Learning outcomes
When you have completed this Unit you should be able to: • • • • • • • describe what is meant by EMS discuss EMSs within the context of adaptive management discuss the differences between ISO 14001 and EMAS describe the purpose and elements of the ISO 14001 EMS standard and, in general terms, be able to discuss how these may be applied within your organisation discuss the benefits and costs of developing and implementing an EMS discuss the factors that may hinder or facilitate the implementation of an effective EMS discuss the criticisms of ISO 14001 as an agent for achieving reduced environmental impacts and improving sustainability
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Why do we need environmental management systems?
As we have discussed in the first two Units, today’s organisations face a wide array of pressures regarding their environmental performance that were simply not part of business concerns in the past. Some of these pressures are reactive – responses to meeting legislative requirements, government policies, economic tools (such as taxes) or community/customer demands. Others are proactive drivers – taking advantage of ‘green’ marketing opportunities by developing and promoting a product or processes that meet strict environmental or sustainability criteria. The pressures on organisations to ‘do better environmentally’ are continuing to rise in line with evidence of increasing pressures on the environment – the result of increasing population and continuing escalation in per capita consumption of goods and energy. To meet these pressures, many organisations have adopted environmental policies and carried out reviews of their environmental impact or audits of their environmental performance. However, as Netherwood (1998, p. 37) points out:
… if the commitments outlined in these policies and the recommendations made in reviews are to be honoured, these organizations will be faced with the problem of finding a systematic way of implementing commitments to environmental management within their existing organizational structure. Indeed, many organizations having written their environmental policy and carried out an initial environmental review, find difficulty in translating recommendations into action.
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Adaptive management and EMSs
One response to this problem is the development of a systematic management system that will deliver the objectives laid out in the entity’s environmental policy. This should follow a cyclic approach of plan–do– monitor–review, described by Standards Australia/Standards New Zealand (2004a) as the plan-do-check-act (PDCA) cycle. This cycle of adaptive management allows for monitoring and review of planned management actions so that learnings and feedback can be incorporated to make improvements. A system for delivering such environmental objectives is an environmental management system (EMS), defined as:
The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.
(AS/NZS ISO 14001:1996)
The following reading outlines the reasons that an organisation should develop an EMS and provides an introduction to the elements of systematic management. Although this reading is directed specifically at local government and service sector organisations, the general principles outlined in this extract are relevant to any organisation of any size. Complete Reading 3.1 and undertake Exercise 3.1. Reading 3.1 Institute of Environmental Studies, 1997, Taking Action. A Guide to Systematic Environmental Management for Local Government and Commercial/Service Sector Businesses, UNSW IES, Sydney, pp. 6-16.
Exercise 3.1
Start to think about your organisation and the environment in a systematic way as suggested in Reading 3.1. You may work in a small organisation that has thought little about the environment to date – in this case, your views on the following questions may be ‘first-time’ thoughts. Or, you may belong to a major corporation that has a well-entrenched EMS. In this case, your considerations of the following questions will be a review of what is already in place.
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What direct impacts does your organisation have on the environment? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ What indirect impacts does your organisation have on the environment? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ Does your organisation already have an environmental policy? If yes, for how long has it been in place? How is it regarded by employees? By senior management? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ 3. 2.
1.
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Does your organisation have an EMS in place? If so for how long has it been in place? How is it regarded by employees? By senior management? Do you think it is effective in achieving the policy objectives? If your answer to the latter is ‘no’, why do you think it is not effective? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ Whether or not you have an environmental policy and an EMS in place, what do you think are likely to be the key reasons/benefits for introducing a policy and an EMS? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ What disadvantages may come from introducing an environmental policy and an EMS? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ 6. 5.
4.
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EMS standards
As outlined in Reading 3.1, while it is possible to simply develop an EMS for your organisation following your own common sense, during the midto late 1990s, certain organisations developed formal standards for EMSs. A standard as defined by ISO (cited in Starkey 1998, p. 63) is a:
… document, established by consensus and approved by a recognized body, that provides, for common and repeated use, rules, guidelines or characteristics for activities or their results, aimed at the achievement of the optimum degree of order in a given context.
The key standards for EMSs are ISO 14001 and EMAS. The best known is ISO 14001, and its accompanying Guide 14004, which belong to the ISO 14000 series aimed at helping organisations in their environmental management and performance. We will briefly explore the nature of the ISO 14000 series and trends in development of new 14000 standards. We will also describe the origins of EMAS and its structure, and provide a comparison with ISO 14001. The remainder of this Unit will be restricted to discussion of ISO 14001 (and its accompanying guide 14004).
ISO 14000 series of standards
Two forces came together at the 1992 Earth Summit in Rio to set in train the development of the ISO 14001 standard. In preparing for the summit, the Business Council for Sustainable Development (BCSD) concluded that business needed to develop international standards on environmental performance so that organisations operating around the world could do so on a level playing field (Hortensius & Barthel 1997). At the same time, there was recognition that the proliferation of product eco-labels of varying types that were springing up in many countries had the potential to cause harmonisation problems for international enterprises, as well as marketplace bias between nations (Cascio, Woodside & Mitchell 1996). For these reasons, the International Organization for Standardization (ISO) was asked to make a commitment to create international environmental standards. (ISO is an international non-government body based in Geneva, formed soon after World War II. It has over 100 member countries represented by national standards institutes, for example, Standards Australia. ISO describes its role as developing voluntary technical standards that add value to all types of business operations, contributing to
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making the development, manufacture and supply of products and services more efficient, safer and cleaner, making trade between countries easier and fairer. ISO develops only those standards which are required by the market, the work being carried out by experts ‘on loan’.) As a result, the ISO formed the Strategic Advisory Group on the Environment (SAGE), which considered all areas of environmental management and performance where the development of international standards might be beneficial for business (Hortensius & Barthel 1997). SAGE did not have the authority to develop such standards itself, but could recommend to the ISO that a new technical committee be established to develop international standards in environmental management. This recommendation was announced at the 1992 Earth Summit and Technical Committee 207 (TC207) was established in 1993 to develop environmental management systems and tools in a number of areas. Consequently, today there is a range of international voluntary environmental management standards falling within the ISO 14000 series. The first of these appeared in 1996 and dealt with EMSs – ISO 14001, the topic of this Unit. In the words of ISO in relation to the 14000 ‘family’ (undated, c):
The whole ISO family provides management tools for organizations to control their environmental aspects and to improve their environmental performance. Together these tools can provide significant tangible economic benefits including: • Reduced raw materials/resource use • Reduced energy consumption • Improved process efficiency • Reduced waste generation and disposal costs; and • Utilization of recoverable resources.
ISO 14001 addresses not only the environmental aspects of an organisation’s processes but also those of its products and services. Environmental aspect is the term used in ISO 14001 (Standards Australia/Standards New Zealand 1996a, p. 1) to describe an “element of an organisation’s activities, products or services that can interact with the environment. A significant environmental aspect is one that has or can have a significant environmental impact”. TC207 has developed further tools to assist in addressing these aspects. For example, Life Cycle Assessment (LCA), which brings a cradle-tograve approach to identifying and evaluating environmental aspects of a product or service, is covered by the 14040 series. Environmental aspects associated with design and development are addressed in ISO 14062. The family of 14000 standards and their roles and relationships to one another are shown in Figure 3.1.
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(http://www.iso.ch/iso/en/prods-services/otherpubs/iso14000/model.pdf) [Accessed November 2006; url invalid 29 April 2008] Figure 3.1: The ISO 14000 Model
ISO notes that while the standards in the 14000 family are designed to be mutually supportive, they can also be used independently. The ISO 14000 family continues to evolve, with two new developments being ISO 14063:2006 in relation to an organisation’s communication of its environmental performance, and plans for a standard on measurement of greenhouse emissions at the project level.
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There is also a move to sector-specific standards, and a possible future standard for corporate social responsibility reporting (which would eventually become sector-specific). A further change is the replacement of the first generation of environmental auditing standards in the 14000 series (14010) by ISO 19011 – EMS auditing. • ISO 14001: This standard specifies requirements for an EMS against which an organisation may be certified by a third party (Hortensius & Barthel 1997). As discussed in the preceding sections, the elements of ISO 14001 comprise a number of steps in a cyclical framework leading to a process of continual improvement in environmental performance. ISO 14004: This is a ‘guidance’ document, providing additional information for organisations embarking on the process of setting an EMS in place. It provides a series of prompts and issues to consider for each of the elements of ISO 14001 and so is a very useful complement to ISO 14001. Copies of 14001 and 14004 cannot be included here for copyright reasons. If not held by your organisation, you might consider suggesting they be acquired. For details on how to purchase see the ISO website:
[Accessed 29 April 2008] •
•
The following website is a good place to seek answers to any questions you may have regarding the 14000 series: [Accessed 29 April 2008] Note that as a UNSW student you have access to the library’s Standards Database via Sirius, the gateway to electronic resources. If you require assistance, refer to the MBT’s library tutorial:
•
EMAS & ISO 14001: BS 7750 is the British Standard for EMSs which was developed in the early 1990s and published in 1992 as the world’s first environmental management standard. It was revised in 1994 to make it compatible with EMAS (Starkey 1998). ISO 14001 drew strongly on BS 7750 and indeed the two standards are very similar. BS 7750 was withdrawn in March 1997 in favour of the international standard ISO 14001. EMAS is the EU regulation for EMSs. The European Commission website provides the following information about EMAS:
The EMAS Regulation 1836/93 was first introduced in July 1993 as an environmental policy tool devised by the European Commission, in a step towards the Community's goal of sustainable development. The EMAS scheme was open for voluntary participation by organisations from April 1995 and its scope restricted participation to sites operating industrial activities.
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The EMAS Regulation applies to all 15 EU Member States and the 3 European Economic Area Member States i.e. Norway, Iceland and Liechtenstein, but more and more candidate countries are also implementing the scheme in preparation for their accession to the EU. Originally, the EMAS scheme was site based and open only to companies operating industrial activities, However, EMAS scope has widened and it can now be applied to any organisation which has an impact on the environment. Therefore, participation in the scheme is open to organisations operating in all economic sectors. In 1996, the International environmental management system standard, EN ISO 14001 was published and was recognised as a step toward achieving EMAS.
(http://europa.eu.int/comm/environment/emas/tools/faq_en.htm#iso14001) [Accessed 29 April 2008]
This website also contrasts EMAS and ISO 14001 as follows:
What is the difference between ISO 14001 and EMAS? EMAS goes beyond EN ISO 14001 in a number of ways, requiring the undertaking of an initial environmental review, the active involvement of employees in the implementation of EMAS, and the publication of relevant information to the public and other interested parties. Notable differences include: • Preliminary review: EMAS requires a verified initial environmental review - ISO does not. • Public availability: EMAS requires that the policy, programme, environmental management system and details of the organisations performance are made publicly available as part of the environmental statement. ISO requires only that the policy be publicly available. • Audits: EN ISO 14001 requires audits, although the frequency is not specified nor is the audit methodology set out in as much detail as in EMAS. • Contractors and suppliers: EMAS is slightly more explicit in its control over contractors and suppliers, requiring that procurement issues are addressed and that the organisation endeavours to ensure that contractors and suppliers comply with the organisation's environmental policy. EN ISO 14001 requires that relevant procedures are communicated to contractors and suppliers. In effect there should be no difference. • Commitments and requirements: EN ISO 14001 does not stipulate the extent to which performance must be improved. EMAS specifies that organisations must attempt to ‘reduce environmental impacts to levels not exceeding these corresponding to economically viable application of best available technology’.
(http://europa.eu.int/comm/environment/emas/tools/faq_en.htm#iso14001) [Accessed 29 April 2008]
It is important to note that while EMAS is only available to EU member states, ISO 14001 is applicable worldwide. EU organisations that have ISO 14001 certification can move to EMAS registration by undertaking some additional steps.
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The nature of ISO 14001
Before moving on to explore the components of ISO 14001 and what is required in its implementation, it is important to consider the ‘nature of the beast’. What was in the minds of TC207 members who designed the standard as they set about their task? What types of organisations is ISO 14001 designed for? What is the purpose of ISO 14001?
Principles underpinning ISO 14001
The implementation of an EMS following 14001 specifications is intended to result in improved environmental performance by an organisation. This is expected to happen through regular reviews of the whole EMS, leading to identification of opportunities for improvement and their implementation. In turn, improvements in the EMS are expected to lead to improvements in environmental performance. The ISO outlines the principles that underpinned development of the 14000 series as follows (ISO undated, b): • • • • • • • they must result in better environmental management they must be applicable in all nations they should promote the broad interests of the public and the users of the standards they should be cost effective, non-prescriptive, and flexible, to allow them to meet the differing needs of organisations of any size worldwide as part of their flexibility, they should be suitable for internal or external verification they should be scientifically based and above all, they should be practical, useful and useable
It is clear from this list that ISO 14001 is designed as a one-model-fits-all standard, designed to be used by organisations of all sizes and types. It is also designed to be used in both developing and developed countries, and within these in a diverse range of geographic and cultural situations. As such a generic standard, ISO 14001 cannot deliver an optimum system for each and every organisation. As outlined above, it is best regarded as a common framework which sets minimum standards for a process (note not absolute environmental performance requirements) into which organisations can fit a range of other tools designed to assist them to meet their environmental goals.
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What is the aim of ISO 14001 and the 14000 series?
The overall aim of ISO 14001 is (Standards Australia/Standards New Zealand 2004a, p. iv): “to support environmental protection and prevention of pollution in balance with socio-economic needs”. More specifically, it is intended to: • Provide organisations with the elements of an effective environmental management system that can be integrated with other management requirements to assist organisations to achieve environmental and economic goals. Assess the effectiveness of the procedures in achieving conformance with the set goals. Demonstrate that conformance to others.
ISO 14001 does not ‘establish absolute requirements for environmental performance beyond the commitments, in the environmental policy, to comply with applicable legal requirements and with other requirements to which the organisation subscribes, to prevention of pollution and to continual improvement’
(Standards Australia/Standards New Zealand 2004a, p. v)
• •
As ISO points out, this framework enables two organisations carrying out similar activities but having different environmental performance to each comply with ISO 14001 requirements. There has been much discussion and criticism of the standard regarding this reality. Many would like to see the standard set goals for pollution prevention, technology used or other environmental outcomes (Cascio, Woodside & Mitchell 1996). However, TC207 and others argue that if such requirements were put in place and were stringent enough to meet critics’ requirements, the standard would not be applicable across a wide range of users. For example, small and medium enterprises (SMEs) may be prepared to adopt an EMS as presently specified by ISO 14001, but not one that sets stringent standards for environmental outcomes that they could not immediately meet. Definitions of SMEs vary and may be based on employee numbers, turnover or other parameters. In the European Union a SME has fewer than 250 employees coupled with turnover and balance sheet limits. SMEs contribute significantly to total pollution load – some suggest 70% but this figure is not substantiated (Hillary 2000b). A similar situation may be true for organisations in some developing countries that may not have achieved the same level of environmental performance as equivalent organisations in developed countries.
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The issue is whether it is better to get such organisations on board and committed to continuous improvement, even if from a low level of environmental performance, than left out of this standards system and possibly with no firm environmental commitments other than those imposed by local regulations (which may be either set at a very low level and/or not adequately enforced). It is worth noting that the standard does intend that the implementation of the EMS as a process goal will also result in improved environmental performance, and that the required regular reviews of the EMS will result in improvements in environmental performance (Standards Australia/ Standards New Zealand 1996a). As outlined above, beyond the EMS standard (ISO 14001), the 14000 series aims to standardise some key environmental tools for analysis, such as LCA and labelling, and through ISO 14004 provide broad guidance for a range of environmental management issues.
ISO 14000 series and trade
As stated by TC207, the committee responsible for developing the 14000 series (ISO undated, b):
The intent of environmental management standards has been to develop a common language for environmental issues, so that customers, manufacturers, governments and other organizations can be assured that environmental issues have been taken into account in the activities and products of their trading partners.
However, TC207 also states that:
… standards can be used to limit trade – a fact recognized by the World Trade Organization when it set limits on the use of ‘non-tariff barriers’ to trade. Environmental issues are highly regulated in many countries, and there are pressures in some areas to use regulations, as well as national and regional standards, to exclude goods and services on environmental grounds. On the commercial level, environmentally-related expectations and requirements of purchasers can have a significant effect on purchasing decisions, and can also affect trade. By concentrating on management standards, and by emphasizing guidance over strict specifications in its documents, TC207 has tried to create a positive mechanism for improving trade, while encouraging improvements in environmental performance. Its challenge now is to help ensure that the standards are used as intended, and not as a barrier to trade.
This is an important issue. The ramifications of trade rules for environmental protection is a highly charged issue – as regular demonstrations at World Trade Organization (WTO) meetings attest. It is
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also a very complex issue. However, given its importance for sustainability and the controversy it has aroused, it is important to keep a ‘watching brief’ on trade/environment links.
Relations between ISO 14001 and other management systems
The ISO 14001 standard stresses that the EMS requirements that it specifies “… do not need to be established independently of existing management system elements. In some cases it will be possible to comply with the requirements by adapting existing management system elements” (Standards Australia/Standards New Zealand 1996a, p. vii). There are certainly considerable links between the ISO 9000 series of quality management standards and ISO 14001. Both are process standards that follow a similar plan–do–monitor–review cycle. The ISO 9000 standards do not address the quality of the product produced by the organisation, but rather, the quality of the process used and, hence, its effectiveness in consistently delivering the product at the standard set by the organisation (responding to customer preferences). Similarly, as we have seen, the ISO 14001 standard is about the effectiveness of the management system for delivering the environmental outcomes set by the organisation. It is not about specifying those environmental performance outcomes. It would seem logical that in implementing ISO 14001, organisations first examine how such a system may fit within their current management frameworks and with other systems, such as quality management or occupational health and safety. This is critical for SMEs, where resources for systems implementation are likely to be scarce, as neither the funds nor personnel are likely to be available to implement three distinctly separate systems. However, beyond the resources issue, having a seamless management system that covers all these areas is definitely desirable in terms of efficiency – and to prevent confusion through overload. The latest version of ISO 14001 in 2004 was been rewritten to enhance the compatibility of the two standards ISO 14001:2004 and ISO 9001:2000 (Brown & Associates, in Thomas 2005). If an EMS is to be successful, it is necessary that it has the commitment of management at the highest level. This is important so that the required time and resources can be allocated for implementation of the system, and for environmental concerns to achieve the necessary priority within the organisation.
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Elements of ISO 14001
The elements of ISO 14001 comprise five steps in a cyclical framework aimed at continual improvement. These steps, shown in Figure 3.2 in the same diagrammatic form as used in the ISO 14001 standard, are: 1. 2. 3. 4. 5. Environmental policy Planning Implementation and operation Checking and corrective action Management review
Each of these steps in turn involves a number of steps, and these are briefly discussed below.
(Hortensius & Barthel 1997, p. 24) Figure 3.2: Environmental Management System Model for ISO 14001
Before we start on these five steps, ISO 14004 (the Guidelines document for 14001) suggests that the organisation carry out an initial environmental review.
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Initial environmental review
Common sense tells us that we will not be well-placed to start our EMS process until we know something about our organisation’s impacts on the environment and the context within which it operates – legislative, community expectations, and so on. We can’t sensibly carry out even the first step of outlining a policy until we have some basic information on these matters. Accordingly, ISO 14004 – the Guidelines for 14001 – suggests that an initial environmental review be performed. The Guidelines recommend that the review may consider the following (Standards Australia/Standards New Zealand 1996b, p. 5): • • • • • • • • • identification of legislative and regulatory requirements identification of environmental aspects of its activities, products or services so as to determine those that have or can have significant environmental impacts and liabilities evaluation of performance compared with relevant internal criteria, external standards, regulations, codes of practice and sets of principles and guidelines existing environmental management practices and procedures identification of the existing policies and procedures dealing with procurement and contracting activities feedback from the investigation of previous incidents of noncompliance opportunities for competitive advantage the views of interested parties functions or activities of other organisational systems that can enable or impede environmental performance
Exercise 3.2
Exercise 3.1 asked you to think about the impacts of your organisation on the environment – clearly an important part of the initial environmental review. Now consider: Who are likely to be the interested parties in relation to your organisation and its environmental impacts? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________
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1.
Can you identify any opportunities for competitive advantage through implementing an EMS and achieving better environmental performance? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________
2.
Environmental policy
An environmental policy is defined (Standards Australia/Standards New Zealand 1996a, p. 2) as a:
Statement by the organisation of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets.
Such policies should be publicly available, prominently displayed and communicated to all employees. It is typically a fairly brief document; a good example is from BHP Billiton. The policy is available on the company’s website, so is clearly intended to be freely available.
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Table 3.1: BHP Billiton’s Sustainable Development Policy At BHP Billiton our objective is to be the company of choice - creating sustainable value for our shareholders, employees, contractors, suppliers, customers, business partners and host communities. We aspire to Zero Harm to people, our host communities and the environment and strive to achieve leading industry practice. Sound principles to govern safety, business conduct, social, environmental and economic activities are integral to the way we do business. Wherever we operate we will develop, implement and maintain management systems for sustainable development that drive continual improvement and ensure we: • • • • • • • • • • • do not compromise out safety values, and seek ways to promote and improve the health of our workforce and the community identify, assess and manage risks to employees, contractors, the environment and our host communities uphold ethical business practices and meet or, where less stringent than our standards, exceed applicable legal and other requirements understand, promote and uphold fundamental human rights within our sphere of influence, respecting the traditional rights of Indigenous peoples and valuing cultural heritage encourage a diverse workforce and provide a work environment in which everyone is treated fairly, with respect and can realise their full potential set and achieve targets that promote efficient use of resources and include reducing and preventing pollution enhance biodiversity protection by assessing and considering ecological values and land-use aspects in investment, operational and closure activities engage regularly, openly and honestly with people affected by our operations, and take their views and concerns into account in our decisionmaking develop partnerships that foster the sustainable development of our host communities, enhance economic benefits from our operations and contribute to poverty alleviation work with those involved through the lifecycles of our products and byproducts to promote their responsible use and management regularly review our performance and publicly report cur progress.
In implementing this Policy, we will engage with and support our employees, contractors, suppliers, customers, business partners and host communities in sharing responsibility for meeting our requirements. We will be successful when we achieve our targets towards Zero Harm, are valued by our host communities, and provide lasting social, environmental and economic benefits to society. (http://www.bhpbilliton.com/bbContentRepository/sdpolicy.pdf) [Accessed 29 April 2008]
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As already noted, an organisation’s environmental policy needs to have top management commitment to its implementation and to its regular review. Exactly what comprises ‘top management’ will no doubt vary from organisation to organisation. For example, where there are multiple operating units it may make sense to treat each as a separate organisation and to have separate policies being driven by managers of individual units (although under the umbrella of an organisation-wide generic policy). In this case each unit would be operating an EMS under ISO 14001. However, while top management commitment is vital to ensure that the policy and the EMS are taken seriously and properly resourced, it is equally vital that the policy (and the EMS) be ‘owned’ by personnel at all levels of the organisation. The policy must also be appropriate to the scale and nature of the organisation and its activities. A key question is how an organisation makes a start in preparing its policy and in deciding just what is most appropriate to the organisation. Clearly, the policy must be framed so that the organisation meets any relevant legislative requirements or any other requirements to which it is committed. For example, the organisation may be a member of an umbrella group, such as the Chemical Manufacturers Association, and have endorsed that Association’s ‘Responsible Care Initiative’ relating to environmental, safety and health considerations. A wide range of such binding commitments exists nowadays, as well as an ever-increasing number of non-binding policies and strategies that may be used as sources of inspiration for drafting an organisation’s environment policy (an Australian example is the National Strategy for Ecologically Sustainable Development). The organisation may conduct an initial review to determine a range of factors relevant to drafting the policy, which may include: • • regulatory requirements or other commitments to associations’ policies and guidelines existing environmental aspects (a term in ISO 14001 to describe elements of an entity’s operations that can interact with the environment) of the organisation through its activities or products or services with the aim of identifying those requiring the most attention benchmarking of the organisation’s environmental performance against relevant codes, standards, the performance of like organisations, internal standards and aspirations existing practices for environmental management policies relating to dealing with other organisations where environmental factors may be relevant - eg, purchasing policies, contractor contracts views of relevant stakeholders
• • • •
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In summary, ISO 14004 lists the following as matters that should be considered for inclusion in an environmental policy: • • • • • • • • organisation’s mission, vision, core values and beliefs requirements and communication with interested parties continual improvement prevention of pollution guiding principles coordination with other organisational policies (eg, quality, occupational health and safety) specific local or regional conditions compliance with relevant environmental regulations, laws and other criteria to which the organisation subscribes
Exercise 3.3
Question 3 in Exercise 3.1 asked you whether your organisation has an environment policy. If your answer was ‘yes’, now consider how well the policy matches these ISO 14001 requirements. Dot point your answer, indicating improvement may be required. If your answer was ‘no’, dot point what you think the contents of an environment (or sustainability) policy should be for your organisation. In deciding what to include, include justification for your choices. ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________
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Planning
This involves the organisation developing a plan to carry out its policy. In order to do this, the organisation clearly has to: • • • • identify its environmental aspects (defined above) and determine which are likely to have significant environmental impacts identify the legal and other commitments relating to the environmental aspects of its products, activities and services set objectives and targets in relation to these significant environmental aspects and to the legal and other commitments put in place an environmental management program for achieving these objectives and targets
We will now briefly examine each of these stages.
Environmental aspects, and legal and other commitments
The planning section of the standard (Cascio, Woodside & Mitchell 1996, p. 107) requires the organisation to: • • establish a procedure to identify the environmental aspects of its operations establish a procedure to identify legal and other requirements to which the organisation subscribes
With regard to identifying environmental aspects, the organisation is required to ensure that it has in place procedures to keep track of any changes in its commitments and regulatory requirements, as well as the environmental aspects of its operations (ie, environmental impact). Regarding the latter, an organisation is only expected to address those issues that it can control, or over which it can be expected to have some influence. Regarding the former, if the organisation does business in a number of countries, it will need to keep abreast of any relevant requirements in each of those countries. With regard to the environmental aspects and associated impacts, Cascio, Woodside & Mitchell (1996, pp. 108-109) provide the following example lists.
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Examples of Environmental Aspects • Waste generation • Wastewater discharge • Stormwater discharge • Point source air emissions • Fugitive air emissions • Automobile exhaust emissions • Chemical use operations • Water use operations • Energy use operations • Use of natural resources • Product obsolescence • Product disposal Examples of Environmental Impacts Impacts on ecology • Impacts on flora • Impacts on fauna • Impacts on biological diversity • Impacts on habitat • Impacts on landscape and natural beauty • • • • • • • • • • • • • • • Impacts on natural resources Impacts on agricultural land Impacts on forest resources Impacts on water supplies Impacts on minerals Impacts on marine resources Impacts on energy resources Impacts on wetlands Impacts on rain forests Impacts on wilderness Impacts on pollution Impacts on air Impacts on water Impacts on radiation levels Impacts on soil erosion Impacts on waste generation Impacts on contamination levels.
These are just some examples of what should be included in consideration of environmental aspects and associated impacts. They will clearly vary depending on the nature of the organisation, its key activities and the locations where these are carried out (see Unit 4 for discussion of impacts of human activities on the environment). Also note that the consideration of environmental impacts should extend from within an organisation to the global system, for example the organisation’s contributions to the Enhanced Greenhouse Effect (Cascio, Woodside & Mitchell 1996).
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An example of some specific aspects and impacts of the activities of the Port of Brisbane is presented in Table 3.2 below.
Table 3.2: Example of Environmental Aspects and Impacts - Port of Brisbane
Aspect Hosing down the deck of a vessel resulting in the discharge of sediments, oils and greases into the waterway Spills of fuels and oils from parked vehicles entering the waterway or paved areas through stormwater flows Purchase of materials and equipment without due consideration for environmental sustainability (ie. Excessive packaging, hazardous waste by-products, excessive noise generation)
Impact Contamination of the waterway through increased turbidity and contaminants Contamination of the soil, ground and surface waters Depletion and inappropriate use of natural resources
(http://www.portbris.com.au/health/environment/environmental_management_sy stems/aspect_and_impacts) [Accessed March 2008]
Environmental objectives and targets
ISO 14001 defines environmental objectives and targets as follows: • • An environmental objective is an “overall environmental goal, arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable”. An environmental target is a “detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives”.
With regard to environmental objective and targets, Cascio, Woodside & Mitchell (1996, p. 113) give the following example of the distinction between the two:
Objective: Reduce effluents and emissions Targets: Evaluate and implement targets for reducing effluents and emissions according to the following schedule: • 33% reduction of hazardous waste by 2002 • 50% reduction of hazardous waste by 2005 …
The Guidelines to Standard ISO 14004 note that setting up of measurable performance indicators should be considered by the organisation to judge progress towards meeting the targets. Note also that the objectives and targets should be a reflection of the environmental policy as well as ongoing consideration of environmental aspects and impacts of the organisation.
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The final part of planning is the establishment of an environmental management program (EMP).
Environmental management program
An EMP provides a framework for the various elements necessary to ensure that environmental objectives and targets are achieved, and to ensure continual improvement (Cascio, Woodside & Mitchell 1996). ISO 14004 notes that to be most effective, the EMP should be integrated into the organisation’s strategic plan. The EMP should state the timeframe for the achievement of objectives and targets, and should identify the people responsible for achieving them (Starkey 1998). Cascio, Woodside & Mitchell (1996, p. 114) advise:
Typical elements found in an environmental management program: management structure, responsibilities, organisation and authority environmental management business processes resources (people and their skills, financial resources, tools) process for setting objectives and targets to achieve environmental policies operating procedures and controls training measurement system and auditing management review and oversight
Importantly, in terms of the criticisms of ISO 14001, Cascio, Woodside & Mitchell (1996) note that there is no requirement for communicating information about objectives and targets, or successes or failures with regard to achieving these within the timeframes set in the EMP.
Implementation and operation
The EMS requires more than the establishment of the plan as outlined above. Cascio, Woodside & Mitchell (1996, p. 117) make the following important point in this regard:
A company can have the loftiest of environmental policies and goals and the best-laid plans for environmental excellence, yet run into a major environmental problem because of inadequate implementation and operation of an environmental management system (EMS). The major catastrophes of the last decade, including large oil spills and industrial explosions, exemplify this possibility. These types of situations can occur quickly, create extremely negative public reactions, and leave lasting damage to an organization’s financial position and reputation. Almost all the world’s recent environmental tragedies have stemmed from breakdowns in the process management system and, most commonly, from inadequate attention to some aspect of the organization’s operations.
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There are a number of elements in ISO 14001 that relate to implementation and operation of the EMS. We will briefly discuss these now.
1. Structure and responsibility
The EMS must be given an important position within the organisation. It should driven by policy, which must be seen not just as a ‘piece of paper’, but a living document that really influences the way the organisation goes about its business. The policy, and the EMS more broadly, must have top management support but must also have real meaning right throughout the organisation and be seen to influence the way in which activities are carried out, products designed and strategy formulated. Accordingly, the way in which the EMS fits into the overall management of the organisation must be clear and transparent to all staff. Flowing from this, environmental responsibilities within the EMS must be clearly assigned to specific managers, and described and documented. These people will need to make sure the various elements of the EMP are carried out at the due time and in an appropriate manner, and they need to report on the achievement of this to senior management, highlighting any areas that need improvement. This is a means of not only avoiding failures in the system, but also helping the entity to achieve continual improvement. Such managers may well have roles other than their environmental management responsibilities; indeed, there is good reason to ensure that this is the case so that the EMS becomes fully integrated throughout the organisation and is not seen as just involving a separate, possibly new group of people. The EMS must necessarily be properly resourced for it to be effective. Such resources include adequate funding, but also and importantly, human resources to provide any specialist skills or equipment required, and training of all employees to effectively contribute to the EMS.
2. Training, awareness and competency
All members of the organisation whose work-related activities may cause a significant impact on the environment must receive appropriate training. ISO 14001 lists areas personnel need to receive awareness training about (Cascio, Woodside & Mitchell 1996, p. 120): • • • The importance of conformance with the environmental policy and procedures and with the requirements of the EMS. The significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance. Their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the EMS, including emergency preparedness and response requirements.
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•
The potential consequences of departure from specific operating procedures.
The organisation should ensure that employees who carry out tasks that could lead to significant environmental impacts are competent to carry out those tasks. Such competency may come from special training or from previous experience. Cascio, Woodside & Mitchell (1996) note that it is important to fully document all training – content, training dates and who received the training. Also, it may be important to consider whether appropriate training has been given to any external contractors or suppliers due to the possibility that their products and/or services could result in environmental impacts for the organisation.
3. Communication
ISO 14001 stresses the importance of both internal and external communication in relation to environmental aspects and EMS. Internally, the organisation must be sure that adequate communication about the EMP occurs between the various sections and different levels of staff. Externally, it is important to have good two-way communication with all stakeholders – neighbours, customers and other interested parties. The organisation should have a documented system for receiving comments and questions from external parties and for responding to these. It should also reach a decision about an ongoing process of communication with external stakeholders about significant environmental aspects and its EMP. That decision should be recorded and acted upon at the set times. Cascio, Woodside & Mitchell (1996) suggest a number of processes for such communication, including: • • • • open days newsletters annual report – could be a stand alone environmental report, or part of the corporate annual report use of a free telephone enquiry line
Importantly, the communication strategy needs to be carefully tailored to suit the nature of the organisation’s activities that may impact on the environment, and the level and scope of stakeholder concern and interest.
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4. EMS documentation and document control
The EMS needs to be properly documented, such documentation needs to describe the EMS as a system with component parts and to show the relationship between these parts. It is imperative that such documentation be kept up to date. When the system is audited for, say, certification, it is vital that the documented description of the system matches what is actually happening! Hence, it is essential that there is a system for storing the documentation (electronic or paper-based), ensuring it is dated, and that obsolete sections are removed and replaced with up-to-date versions. It is also important that the documentation is readily available in the places it will be needed for effective operation of the EMS.
5. Operational control
The organisation will have identified aspects that could lead to significant environmental impact and will have developed objectives and targets associated with these. This section of the Standard requires that operating procedures are documented “to cover situations where, if no procedures existed, the objectives and targets might not be met” (Starkey 1998, p. 73). The organisation is also required to establish procedures relating to significant aspects of goods and services that the organisation uses and that are supplied externally. Naturally, these procedures need to be communicated to the relevant suppliers and contractors.
6. Emergency preparedness and response
The operational control procedures set in place the means to avoid significant environmental impacts in line with targets. However, things do go wrong and this section of the EMS aims to ensure that if this does occur, procedures will be in place to minimise any possible resultant environmental impacts. The Standard requires that procedures be in place to identify the potential for such accidents and to set in place response procedures that will minimise any environmental impacts. The Standard also requires that such emergency procedures be reviewed and revised from time to time and that should any incidents occur, lessons are drawn from them. It is also necessary that emergency procedures be tested regularly for effectiveness.
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Checking and corrective action
This section is about both measuring the performance of the EMS and taking corrective action if it is seen to be deficient. There are four sections to this part in ISO 14001 – we will briefly consider each.
1. Monitoring and measurement
Monitoring and measurement provides the means to check on progress towards meeting targets. • • • • This needs to occur continuously or at regular intervals which are appropriate to the parameter/issue being tracked. It must cover all characteristics of operations and activities that may have a significant impact on the environment. These characteristics include information to track performance, information relating to operational controls and information regarding conformance with the set objectives and targets. All monitoring equipment must be regularly calibrated and this must be documented.
As well, the organisation needs to have in place a procedure for regularly evaluating compliance with relevant environmental legislation.
2. Nonconformance and corrective and preventive action
Nonconformance refers to deviations from the EMS and from requirements of ISO 14001 and should not be confused with noncompliance. The term noncompliance is used for deviations from country law and regulations.
(Cascio, Woodside & Mitchell 1996, p. 138)
Nonconformance refers to activities or outcomes that are not in line with the policy, objectives, targets, record keeping, training, or indeed, anything specified as part of the EMS. It is necessary to seek out the cause of the nonconformance and identify the options for corrective and preventive action, as well as taking action to mitigate any impacts caused. Any changes in procedures that may result must be documented. The Standard emphasises that the corrective or preventive action must be at an appropriate level to the problems and environmental impact caused.
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3. Records
Records are vital to the EMS since they not only set out procedures and changes and the results of monitoring, but they also allow the organisation to demonstrate conformance to the ISO 14001 Standard. Records will include information on procedures, records of training, results of audits, monitoring records, reports of incidents or complaints, procedures for emergency preparedness and response, etc. The records must be appropriately stored and readily retrievable.
4. EMS audit
The audit is to check whether the EMS of the organisation conforms to the requirements in the Standard, and whether it has been properly implemented and maintained. Importantly, the audit also supplies information to management on the results of the audit. There should be audit program procedures in place relating to: • • • • scope of the audit methodologies who will conduct the audit report on the results
The frequency of the audit should also be specified – this will be based on the results of previous audits and the nature of the organisation in relation to environmental aspects and related impacts. The audit may be conducted by people within the organisation or by a third-party team from outside. Cascio, Woodside & Mitchell (1996) emphasise that this is an audit of the EMS – not of environmental performance. As mentioned above, this is one of the criticisms of ISO 14001.
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Management review process
A review of the EMS needs to be conducted by management at appropriate intervals to check whether the EMS is: • • • still suitable adequate effective
Both internal and external factors may change over time, requiring changes to the EMS. The management review process has to ensure that all the necessary information is available to enable management to carry out this review. Internally, this may include the performance of the organisation against its objectives and targets, changes in work processes or suitable technologies, and any relevant incidents. Externally, there may be changes in regulations, market preferences or stakeholder views. In summary:
… the outputs from management reviews shall include any decisions and actions related to possible changes to environment policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement.
(Standards Australia/Standards New Zealand 2004a, p. 9)
This review is also central to the requirement for continual improvement embedded in ISO 14001, to be achieved by:
An organisation should continually evaluate its environmental performance and the performance of its environmental management system processes to identify opportunities for improvement.
(Standards Australia/Standards New Zealand 2004b, p. 33)
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Certification or self-declaration
Having been through the plan–do–monitor–review cycle, the organisation needs to decide what type of recognition it wants for the EMS. As the organisation has gone to the trouble of putting an EMS in place, it will, as a minimum, want to demonstrate to itself that the system is intact and working effectively. Such ‘self-declaration’ involves an internal check of compliance with the ISO 14001 requirements. However, there may be a range of reasons that an organisation wishes to seek external, independent, third-party checking for compliance with ISO 14001. Such auditing by an accredited certifying body 1 will provide certification to ISO 14001 for the organisation. Reasons why an organisation may want third party certification include: • • • to gain a market advantage through demonstration to customers that the organisation has an independently certified EMS to qualify as a supplier of goods or services to other organisations which may demand such certification as a catalyst to improving the EMS and identifying and reducing environmental risks
Nevertheless, EMS certification will cost the organisation both time and money, and the organisation will need to weigh up the costs and benefits.
1
An accredited certifying body is an entity that has been accredited to carry out certification activities (to ISO 14001). This means it is judged competent, both as an organisation and by virtue of its employees having relevant skills and experience, to carry out certification of EMSs. Within Australia, JAS-ANZ acts as an accreditation body – it is a not for profit, self-funding organisation, established in 1991 under a Treaty between Australia and New Zealand to act as the joint accreditation body for those 2 countries for certification of management systems, products and personnel. Unit 3 Environmental Management Systems
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Uptake of ISO 14001
The ISO does not itself issue certificates for ISO 14001, but regularly undertakes surveys of uptake of certification to 14000. Table 3.3 shows the world growth in ISO 14001 certification – and Australia’s share. The overall growth is steady, the number of countries involved showing steady growth as well. Europe (43%) and the Far East (42%) held the bulk of certifications in 2005. It is interesting to note that the share of certifications for the Far East increased from 16% in 1997 to 42% in 2005. As shown in the table, Australia and New Zealand’s combined share of the world total increased through the period 1995-9 to a high of 5.46%, but has since declined to 1.76% in 2005. Nevertheless, it is still high relative to the size of these two countries. (By contrast, in 2002 only 9.6% of certificates were held in North America, comprising the US, Canada and Mexico). In 1999, Australia ranked fifth in the total number of new certificates for that year (356 in total, the greatest growth being Japan with 1,473 new certificates in 1999).
Table 3.3: World Growth in ISO 14001 Certification, and Australia’s Share
World results World total World growth No. of countries Japan USA Germany India Australia/ New Zealand Share in % for Aust/NZ Australia New Zealand 1 Mar ’95 56 19 Dec ’95 257 Dec ’96 1,491 1,234 45 Dec ’97 4,433 2,942 55 713 79 352 28 163 Dec ’98 7,887 3,454 72 1,542 291 630 40 385 Dec ’99 14,106 6,219 84 3,015 636 962 111 770 Dec ’02 49,440 12,684 117 10,620 2,620 3,700 605 1,563 Dec ‘05 111,162 21,225 138 23,466 5,061 4,440 1,698 1,958 Dec ‘06 129,199 18,037 140 22,593 5,585 5,415 2,016 2,146
0.39 1 Mar ’95
3.76 53 3
3.68 137 26
4.88 352 33
5.46 708 62
3.16 1,485 78
1.76 1,778 180
1.66 1,964 182
( )
[All Accessed 29 April 2008]
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Barriers and drivers to uptake of EMSs
The factors influencing establishment of an EMS – and beyond that, a decision to apply for certification – are many, and will vary considerably depending on the nature and size of the organisation. Morrow & Rondinelli (2002, p. 163) report on some drivers and motivators for the adoption of EMSs by manufacturing companies:
In one of the few large-scale surveys of companies adopting EMS and pollution prevention practices, Florida and Davidson (2001) asked executives of 214 manufacturing companies in Pennsylvania what motivated them to do so. They found that among the high adopters commitment to environmental improvement was the strongest motivator (91.9%), followed by the opportunity to attain corporate goals and objectives (88.7%), economic benefits and improved business performance (87.1%), State and federal regulatory climate (85.5% and 83.9) and improved community relations (85.5%).
SMEs are the key sector in the economies of most nations, making up more than 90% of all enterprises (Hillary 2000b). Rather than large organisations, SMEs will probably see more barriers to the adoption of an EMS – resources will be fewer and the costs of implementation in both money and personnel terms may be seen as too high. It is therefore worth devoting some of our attention here to this particular sector. One issue that is often seen as a barrier for SMEs is the high level of documentation and the bureaucratic approach perceived to be required for certification to ISO 14001. However, Hillary (2000a) argues that there is nothing in the requirements for 14001 that necessitates the development of a complex or bureaucratic system. In contrast, she suggests that it is possible to meet 14001 requirements through an effective system that is both simple and user-friendly, and cites Annexure A of ISO 14001 in support of her case (2000a, p. 100):
… the level of detail and complexity of the environmental management system . . . and the resources devoted to it will be dependent on the size of the organisation and the nature of its activities. This may be the case in particular SMEs.
In regard to a UK consultant on this issue, she states:
His view was that bulging manuals and bureaucratic, unwieldy systems were caused not by the requirements of the standards but by the inappropriate implementation of the standard by consultants.
(Hillary 2000a, p. 100)
Of course, whether an organisation decides to develop an EMS – and beyond that to apply for certification – will depend on not only the perceived (or real) barriers, but also on the drivers: the perceived benefits from developing an EMS (such benefits have been discussed above, but only in very general terms and not in the context of certification).
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Reading 3.2 highlights some barriers to environmental management within the framework of EMSs, and some strategies to overcome them. Reading 3.2 Kirkland LH & Thompson D, 2002, ‘Analysis of barriers’, in Thompson D (ed), Tools for Environmental Management: A Practical Introduction and Guide, University of Calgary Press, ch. 4, pp. 60-64.
Exercise 3.4
In organisations you are familiar with, have you observed evidence of any barriers to the development of environmental management systems as described in Reading 3.2? If so, were these barriers overcome, and how? If not, can you suggest any useful strategies based on the reading? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________
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In Reading 3.3, Ruth Hillary discusses the experience of SMEs with EMAS and ISO 14001 in the United Kingdom. In particular, she reports on two surveys of SMEs in the UK and continental Europe covering their views on internal and external benefits, ‘disbenefits’, and barriers to EMS adoption. Reading 3.3 Hillary R (ed), 2000, Small and Medium-sized Enterprises and the Environment: Business Imperatives, Greenleaf Publishing, Sheffield, pp. 135-145. Reading 3.4 is a case study for Argyle Diamond Mines, a large mining organisation in Western Australia. The case study outlines the driving forces for development of an EMS, and provides a reflection on the experience with each stage of the process. It also considers costs and benefits and the key lessons learned from the experience. (The Sullivan & Wyndham text contains a number of Australian case studies on EMS implementation and is recommended as a good source for comparative case studies of EMS implementation in different types of organisations.) Reading 3.4 Knol R, 2001, ‘Argyle Diamond Mines’, in Sullivan R & Wyndham H (eds), Effective Environmental Management: Principles and Case Studies, Allen & Unwin, Sydney, ch. 7, pp. 136-156. Morrow & Rondinelli (2002) under took five in-depth case studies of smaller domestic energy and gas companies in Germany to explore the benefits of adopting and certifying EMSs and some of these results have been illustrated in Table 3.4 below.
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Table 3.4: Benefits of Adopting and Certifying EMSs Benefit Better organization and documentation Increased legal certainty Improved image Greater employee motivation Reduced resource use Enhanced plant safety Opportunity to set the example for suppliers Optimization of process flows Improved cooperation with authorities Positive market effects Cost savings Competitive advantages/safeguard of the site More favorable insurance/loans Opportunity to use public funds for development purposes
a
Rating 7.7 7.1 6.9 6.6 5.8 5.7 5.0 4.9 4.5 4.3 4.2 4.0 2.3 2.1
N=1264 Rating: 0=not applicable, 5=partially applicable, 10=fully applicable. (Morrow & Rondinelli 2002, p. 167)
There is now a range of good case studies and links to EMSs on the Internet. The following are worth looking at, however, as urls can disappear, if any of the sites below cannot be accessed, type in ‘EMS case studies’ into a search engine such as Google. • • Public sector cases: [Accessed 29 April 2008] Natural resource sector in Australia: [Accessed 29 April 2008]
Following on from Readings 3.3 and 3.4, search for further useful EMS case studies on the Web using the links above or others you may find. Combine this information with the other material in this Unit so far to answer the following questions.
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Exercise 3.5
1. What are likely to be the key benefits from development and implementation of an EMS to ISO 14001 specifications:
• internally to an organisation ___________________________________________________________
___________________________________________________________ ___________________________________________________________ ___________________________________________________________
• externally to an organisation
___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ Which of these benefits identified are most likely to be relevant for your organisation? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ What are likely to be the key disadvantages to an organisation of adoption of an EMS? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ 3. 2.
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4. Which of these may be most relevant to your organisation? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ What barriers may be encountered in the effective adoption and implementation of an EMS? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ 6. Which do you think may be most significant in your organisation? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ Beyond the answers you have given above, what other key messages have you gained from Readings 3.3 and 3.4 and any other case studies you found on the Web? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ 7. 5.
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Will ISO 14001 lead to lower impacts on the environment?
And what about sustainable development?
It is not possible to answer these questions with any certainty. We have already noted the criticisms of many: that in failing to prescribe environmental performance targets, ISO 14001 cannot guarantee that organisations certified to the standard will demonstrate good environmental performance. However, as we have seen above, commitment to environmental improvement was the strongest motivator for adopting EMSs (Florida & Davidson 2001). Indeed, Netherwood (1998, pp. 55-56) says:
It is theoretically possible for an EMS to be developed by an organization and the standards satisfied, when the organization has an appalling record in environmental terms, by achieving minimum levels of compliance and demonstrating a commitment to continuous environmental improvement, however small that may be.
We have discussed above and read in the readings some of the advantages of having a generalised standard that can be used in many very different situations. As well, we have seen through case studies the distinct benefits that have derived for some organisations from their EMS – benefits both to the environment and the organisation. Reading 3.5 summarises some of these criticisms and also considers what role (if any) EMSs may play as a tool for sustainable development. Reading 3.5 Netherwood A, 1998, in Welford R (ed), Corporate Environmental Management 1: Systems and Strategies, Earthscan, London, pp. 54-59.
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The following table is an extract from Thomas (2005), adapted from Sutton (1997), which compares a standard EMS and a ‘sustainabilityseeking’ EMS.
Table 3.5: Comparison of Standard and ‘Sustainability-seeking’ EMSs Standard Application of ISO 14001 0-Initial environmental review Review of views of interested parties Sustainability-Seeking Interpretation of ISO 14001 1-Review and set direction Values review Review of society’s environmental needs and society’s environmental strategies Reviews of significant negative environmental impacts and aspects for the production and organisation improvement program Requirements review (legal, voluntary) Management Review
Identification of environmental aspects
Legislative and regulatory and voluntary requirements Examination of all existing environmental management practices and procedures with evaluation of feedback from the investigation of previous incidents 1-Environmental policy
Policy development Strategy development Identification of significant environmental aspects for a sustainability-development program
2-Planning Environmental aspects Legal and other requirement Objectives and targets Environmental management programs 3-Implementation and operation 4-Checking and corrective action 5-Management Review
2-Plan
Objectives and targets Environmental management programs 3-Implementation and operation 4-Checking and corrective action (Management review is covered in 1) (Adapted from Sutton 1997, in Thomas 2005)
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Sutton (1997) in Thomas (2005) provides three main differences that set the sustainability-seeking EMS apart from a standard one: 1. 2. 3. A more rigorous framework for setting objectives and targets and the policy may need to be longer than a typical inspirational ‘one pager’. Strategy is developed to assist the organisation to decide how it can help society achieve ecological sustainability while advancing its own competitive interests. Identification of significant aspects of the sustainabilityempowerment program and selection of options that help society achieve sustainability.
Exercise 3.6
Though ISO 14001 can be a valuable internal management tool for organisations, its ability to meet public policy objectives and address societal expectations for corporate accountability is limited.
(Kao-Cushing 2000, p. 7)
In light of Reading 3.5 and the above discussion, what are your views on Kao-Cushing’s comments in this quote? ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________ ___________________________________________________________
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Conclusion
In this Unit, we have described the emergence of environmental management system during the 1990s as a structured and systematic approach to environmental management for an organisation. We also explored the development of formal standards for EMSs, enabling organisations to achieve internationally recognised certification. We noted, however, that the standards developed ensure that set processes are followed. Certification to ISO 14001 allows an organisation to demonstrate that it has a credible EMS that meets the specifications of the standard. However, this does not demonstrate that the organisation has achieved good environmental performance outcomes. The EMS provides a useful framework for this course as a whole, since an examination of the environmental aspects and associated impacts together with the range of other requirements (legal and other commitments) as required by the EMS essentially presents the topics that we will cover in the remaining Units of the course.
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References and further reading
Cascio J, Woodside G & Mitchell P, 1996, ISO 14000 Guide. The New International Environmental Management Standards, McGraw-Hill, New York. Florida R & Davidson D, 2001, ‘Gaining from green management: Environmental management systems inside and outside the factory’, California Management Review, vol. 43, no. 3, pp. 64-84. Hillary R (ed), 2000a, ISO 14001: Case Studies and Practical Experiences, Greenleaf Publishing, Sheffield, UK. Hillary R (ed), 2000b, Small and Medium-Sized Enterprises and the Environment: Business Imperatives, Greenleaf Publishing, Sheffield, UK. Hortensius D & Barthel M, 1997, ‘Beyond 14001. An Introduction to the ISO 14000 Series’, in Sheldon C (ed), ISO 14001 and Beyond. Environmental Management Systems in the Real World, Greenleaf Publishing, Sheffield, England, pp. 19-44. ISO website for information on the ISO 14000 series: [Accessed 29 April 2008] ISO, undated a, International Organization of Standardization, ISO 14000 – Meet the whole family!:
[Accessed 29 April 2008]
ISO, undated b, International Organization of Standardization, What is ISO 14000?: [Accessed 29 April 2008] ISO, undated c, International Organization of Standardization, ISO 14000 Essentials: [Accessed 29 April 2008] Kao-Cushing K, 2000, ‘Why environmental management system standards matter’, Pacific Institute Report, Fall, pp. 6-10.
[Accessed 29 April 2008]
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Morrow D & Rondinelli D, 2002, ‘Adopting corporate environmental management systems: Motivations and results of ISO 14001 and EMAS certification’, European Management Journal, vol. 20, no. 2, pp. 159-171. Netherwood A, 1998, ‘Environmental Management Systems’, in Welford R (ed), Corporate Environmental Management 1: Systems and Strategies, 2nd edn, Earthscan, London, pp. 37-60. Standards Australia/Standards New Zealand 1996a, Environmental Management Systems – Specification with Guidance for Use, AS/NZS ISO 14001:1996. Standards Australia/Standards New Zealand 1996b, Environmental Management Systems – General Guidelines on Principles, Systems and Supporting Techniques, AS/NZS ISO 14004:1996. Standards Australia/Standards New Zealand 2004a, Environmental Management Systems – Requirements with Guidance for Use, AS/NZS ISO 14001:2004. Standards Australia/Standards New Zealand 2004b, Environmental Management Systems – General Guidelines on Principles, Systems and Support Techniques, AS/NZS ISO 14001:2004 Starkey R, 1998, ‘The standardization of Environmental Management Systems: ISO 14001, ISO 14004 and EMAS’, in Welford R (ed), Corporate Environmental Management 1. Systems and Strategies, 2nd edn, Earthscan, London, pp. 61-89. Sullivan R & Wyndham H, 2001, Effective Environmental Management: Principles and Case Studies, Allen & Unwin, Sydney. Sutton P, 1997, ‘Targeting sustainability: The positive application of ISO 14001’, in Sheldon C (ed), ISO 14001 and Beyond: Environmental Management Systems in the Real World, Greenleaf publishing, Sheffield, pp. 211-42. Thomas I, 2005, Environmental Management: Practices and Processes in Australia, The Federation Press, Sydney.
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Readings
Contents
Reading 3.1 Institute of Environmental Studies, 1997, Taking Action. A Guide to Systematic Environmental Management for Local Government and Commercial/Service Sector Businesses, UNSW IES, Sydney, pp. 6-16. Kirkland LH & Thompson D, 2002, ‘Analysis of barriers’, in Thompson D (ed), Tools for Environmental Management: A Practical Introduction and Guide, University of Calgary Press, ch. 4, pp. 60-64. Hillary R (ed), 2000, Small and Medium-sized Enterprises and the Environment: Business Imperatives, Greenleaf Publishing, Sheffield, pp. 135-145. Knol R, 2001, ‘Argyle Diamond Mines’, in Sullivan R & Wyndham H (eds), Effective Environmental Management: Principles and Case Studies, Allen & Unwin, Sydney, ch. 7, pp. 136-156. Netherwood A, 1998, in Welford R (ed), Corporate Environmental Management 1: Systems and Strategies, Earthscan, London, pp. 54-59.
Reading 3.2
Reading 3.3
Reading 3.4
Reading 3.5
Unit 3 Environmental Management Systems
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Unit 3 Environmental Management Systems
Reading 3.1
Institute of Environmental Studies, 1997, Taking Action. A Guide to Systematic Environmental Management for Local Government and Commercial/Service Sector Businesses, UNSW IES, Sydney, pp. 6-16.
Commonwealth of Australia Copyright Regulations 1969 WARNING This material has been reproduced and communicated to you by and on behalf of the University of New South Wales pursuant to Part VB of the Copyright Act 1968 (the Act). The material in this communication may be subject to copyright under this Act. Any further reproduction or communication of this material by you may be the subject of copyright protection under the Act. Do not remove this notice.
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Reading 3.2
Kirkland LH & Thompson D, 2002, ‘Analysis of barriers’, in Thompson D (ed), Tools for Environmental Management: A Practical Introduction and Guide, University of Calgary Press, ch. 4, pp. 60-64.
Commonwealth of Australia Copyright Regulations 1969 WARNING This material has been reproduced and communicated to you by and on behalf of the University of New South Wales pursuant to Part VB of the Copyright Act 1968 (the Act). The material in this communication may be subject to copyright under this Act. Any further reproduction or communication of this material by you may be the subject of copyright protection under the Act. Do not remove this notice.
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Reading 3.3
Hillary R (ed), 2000, Small and Medium-sized Enterprises and the Environment: Business Imperatives, Greenleaf Publishing, Sheffield, pp. 135-145.
Commonwealth of Australia Copyright Regulations 1969 WARNING This material has been reproduced and communicated to you by and on behalf of the University of New South Wales pursuant to Part VB of the Copyright Act 1968 (the Act). The material in this communication may be subject to copyright under this Act. Any further reproduction or communication of this material by you may be the subject of copyright protection under the Act. Do not remove this notice.
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Reading 3.4
Knol R, 2001, ‘Argyle Diamond Mines’, in Sullivan R & Wyndham H (eds), Effective Environmental Management: Principles and Case Studies, Allen & Unwin, Sydney, ch. 7, pp. 136-156.
Commonwealth of Australia Copyright Regulations 1969 WARNING This material has been reproduced and communicated to you by and on behalf of the University of New South Wales pursuant to Part VB of the Copyright Act 1968 (the Act). The material in this communication may be subject to copyright under this Act. Any further reproduction or communication of this material by you may be the subject of copyright protection under the Act. Do not remove this notice.
Reading 3.5
Netherwood A, 1998, in Welford R (ed), Corporate Environmental Management 1: Systems and Strategies, Earthscan, London, pp. 54-59.
Commonwealth of Australia Copyright Regulations 1969 WARNING This material has been reproduced and communicated to you by and on behalf of the University of New South Wales pursuant to Part VB of the Copyright Act 1968 (the Act). The material in this communication may be subject to copyright under this Act. Any further reproduction or communication of this material by you may be the subject of copyright protection under the Act. Do not remove this notice.
Business Management for a Sustainable Environment
Unit 4 The State of the Environment
15-May-08