EMS frameworks up for review
The process of revising and updating both ISO 14001 and EMAS is under way. Much progress has already been made but several hurdles remain to be cleared, finds David Carr
Environmental management systems (EMSs) are frameworks for managing an organisation’s environmental impacts. Designed to integrate with other management systems, they aim to help deliver good environmental management, manage risk and ensure legal compliance.
Implementing an EMS can also help an organisation to better understand its environmental impacts and focus on where they can be reduced. In doing so, an EMS can also deliver cost savings and competitive benefits in the form of more efficient energy, water and transport use, enhanced procurement efficiency and better waste management practice.
But the potential benefits are wider still. An EMS can also assist in communicating an organisation’s commitment to environmental improvement and provide a focus for engagement by staff and stakeholders.
And yet, while most organisations recognise the benefits that an EMS can bring, there remains some debate over their value.
A 2006 survey undertaken by ENDS, the Institute of Environmental Management and Assessment (IEMA), the Environment Agency and UK Accreditation Service collated responses from more than 600 organisations. Seven in ten respondents said that implementing an EMS led to a "significant environmental performance improvement that otherwise would not have been achieved" (ENDS Report 382, pp 30-33). However, one in six (17%) said EMSs made little difference to environmental performance, over and above that achieved by other drivers, while 13% said they delivered only a short-term difference that was not sustained. The survey echoed the findings of a similar one undertaken in 2003 (ENDS Report 347, pp 19-21).
However, more recent evidence from an EU-wide study found that organisations adopting an EMS do tend to raise their environmental performance.1 The researchers, from the Scuola Superiore Sant’Anna in Pisa, Italy, found a strong correlation between an organisation incorporating an EMS and its ability to successfully plan and achieve its environmental targets.
An enhanced environmental performance was also found to be linked to the length of time an EMS has been in place, even though the marginal gains diminish over time.
The study also considered the impact on competitiveness. An EMS fully integrated throughout an organisation was generally found to deliver an enhanced competitive performance. But the length of time that an EMS has been in place was found to not necessarily improve competitiveness. Rather, the key factor was the degree to which the EMS is embedded in the organisation. The researchers concluded that even newly registered organisations could gain competitive benefits, provided the EMS was well implemented and managed.
ISO 14001 and EMAS
While the details of an EMS can vary between organisations, frameworks specifying their requirements are detailed in internationally recognised standards.
In the UK, the most widely adopted is the international standard for environmental management systems, ISO 14001. The EU’s Eco-Management and Audit Scheme (EMAS) is an alternative, though take-up in the UK has lagged that of ISO 14001. The two have developed in tandem and both have been structured so as to be compatible with other standards, particularly the ISO 9001 quality management standard.
ISO 14001 is administered by the Geneva-based International Organization for Standardization (ISO) and was first published in 1996. It aims to strike a balance between an organisation reducing its environmental impact, while maintaining profitability and competitiveness. Its applicability to both private and public sector bodies, manufacturing and service sector companies and organisations of any size has seen its global reach grow, in recent years.
EMAS has been operational since 1995. While originally restricted to industrial companies, it has been available to all organisations in both the public and private sectors since 2001.
Both have their critics. In 2002, Brian Kraus, chief executive of ERM Certification and Verification Services said many environmental managers considered ISO 14001 to be an "irrelevance" with respect to environmental performance. He warned that without effective action, the standard would lose its credibility.
He added that organisations gaining ISO 14001 certification would not necessarily deliver environmental benefits, because they were failing to address real performance factors (ENDS Report 325, pp 3-4). Further evidence of the ‘crisis of confidence’ in ISO 14001 emerged shortly after (ENDS Report 327, pp 31-33).
Criticisms
Other criticisms levelled at ISO 14001 and EMAS are that they do not necessarily guarantee full compliance with environmental regulations all of the time, and that they offer only a framework within which an organisation can set its own objectives. The lack of a clear accounting mechanism and the absence of mandatory reporting requirements have also been flagged up as weaknesses in the ISO 14001 standard.
But steady growth in the take-up of EMSs has been recorded. An organisation can also opt to have its EMS certified. While this is not mandatory, gaining third-party recognition that their EMS meets ISO 14001 or EMAS can deliver benefits, including the confidence that it is robust and is recognised as such by an independent assessor. Certification also helps to demonstrate the organisation’s environmental responsibility to shareholders, the public, regulators, customers and clients.
To ensure and demonstrate consistency and maintenance of standards, certification bodies can be accredited. In the UK, the relevant accreditation body is the UK Accreditation Service (UKAS). Internationally, consistency among accreditation bodies is achieved through the International Accreditation Forum (IAF).
But the certification process has also come under fire and concerns with it have long been apparent. A 2003 survey conducted by ENDS and IEMA collated the responses of a sample of 350 ISO 14001 certified companies, consultancies and certification providers (ENDS Report 347, pp 19-21).
Significantly, almost half (48%) of those polled expressed doubts about the competency of certification bodies at that time. Three years later, evidence of doubts surrounding the certification process remained (ENDS Report 382, pp 30-33).
Nevertheless, steady growth in certification has been maintained. Data in ISO’s Survey of Certifications revealed that globally, more than 154,000 ISO 14001 certificates had been issued by December 2007 – some 26,000 more than a year earlier.
In the UK alone 7,323 ISO 14001 certificates had been issued by the end of 2007, up from 6,070 in 2006, and placing the UK among the top five countries for ISO 14001 certification. But while the data shows growth in the number of certificates issued, it refers to the number of sites covered and not their size, so gaining an accurate measure of the true scale of the growth in ISO 14001 certification remains somewhat elusive. Data to December 2008 will be available shortly and is expected to indicate further growth in certification, especially among service sector firms, retailers and food manufacturers.
One of the main drivers behind the rise of certification is demand from within the supply chain for higher environmental standards. This has been seen particularly in the automotive sector. Car makers have increasingly demanded that their component suppliers be ISO 14001 certified so that the environmental standards of the finished product are enhanced. Government departments, through their procurement activities, have also been a major driver.
New legislation, particularly that related to energy efficiency and climate change, can also encourage certification. For example, organisations are increasingly aware that meeting the requirements of the Carbon Reduction Commitment (CRC) can be easier when a robust EMS is in place. The policy pressure for greener buildings has also accounted for some of the growth in ISO 14001 certification among construction companies in recent years.
Standards development
And while criticisms of ISO 14001 and EMAS have been aired, their refinement and development has sought to address these concerns and enhance their value.
In 2008, the European Commission proposed to revise EMAS, simplify the legislation and reduce the costs and administration burden associated with it, particularly for small and medium-sized enterprises (SMEs).
It set out proposals, including the promotion of EMAS among member states and EU institutions, providing financial assistance to registered organisations, lengthening permit validity and introducing a harmonised system throughout the EU.
Proposals were also made to extend the reach of EMAS to the rest of the world to reflect the global reach of many organisations’ activities. Agreement on the text for the revised EMAS Regulation was reached by the Council and European Parliament in April 2009 and formal adoption is expected shortly.
The process of updating and revising ISO 14001 is also under way. The standard was last amended and updated in 2004, with changes made to definitions and terminology. It was also aligned more closely with the ISO 9001 quality standard at that time and some benefits accrued, according to José Alcorta, secretary of the ISO technical committee responsible for ISO 14001, ISO/TC 207/SC1. "Between 1996 and 2004, there were quite a large number of interpretation queries," he explains. "In the last two years, there has been just one query regarding the ISO 14001 standard, so greater clarity has been achieved."
A systematic review undertaken in 2007 then confirmed the ISO 14001 standard for a further five years. In 2012 a subsequent revision is likely and Mr Alcorta is confident that further enhancements will be delivered then. "We made huge progress in 2004 and the structures are now in place to bring us closer together in the next revision," he says.
But some hurdles stand in the way, not least that of squaring the different views on the way forward. Further aligning the terminology is a key consideration and somewhat problematic, given the global coverage and the need to translate the standard into more than 100 languages. Moreover, while ISO 14001 and ISO 9001 are already compatible, there is further work ahead to align the two standards even more closely.
The task is part of the wider project of bringing all ISO management system standards closer together. This is the job of ISO’s joint task coordination group (JTCG), which is looking at developing identical clause and subclause titles in all management systems standards and developing identical text. "We have a view on where we’re going to go," says Mr Alcorta. "The JTCG is looking for greater commonality between all management systems standards, including ISO 14001."
At the September 2009 Stockholm meeting of the JTCG, a high-level structure for management system standards was agreed.
But further development of the ISO 14001 standard will need much discussion among member countries before agreement is reached. The standardisation process relies on a consensus-based approach that addresses differences of opinion between member countries.
No simple task
This is no simple task, given the 60-plus countries involved, as Anne-Marie Warris, ISO/TC 207/SC 1 chair explains. "We have to recognise that EMS means different things to different cultures and we’re trying for an international standard. It has to be a group decision and consensus brings credibility to the ISO process."
Nevertheless, she is optimistic, adding: "Given the complexity, we’ve come a long way with what needs to be done." A study group has been set up to consider the challenges to be addressed. Work on this commenced in July and a report will be delivered to ISO/TC 207/SC 1 at its next plenary meeting in July 2010.
As well as successfully integrating the conclusions and recommendations of the JTCG into ISO 14001, there is a wider issue at stake she says; that of recognising the impact of the changed economic landscape, the rise of globalisation and how the shift towards an increasingly service-sector based economy impacts on ISO 14001’s development. "The way we work has changed and organisations have changed," concludes Dr Warris "and the changes made to ISO 14001 must address this."