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Intended to organize and restructure a company's environmental systems to foster continuous improvement, ISO 14000 offers various benefits —reduced regulatory oversight, increased management efficiencies, easing of command and control requirements —to organizations that comply with its guidelines. Though compliance and subsequent certification are not mandatory, lack of certification can mean the potential loss of market share —both here and abroad —to corporations that have embraced the new management standards.
Written and structured to help you understand the implications of ISO 14000 international environmental management standards on your business, this concise and user-friendly reference addresses 250 crucial questions about ISO 14000 and ISO 14001, a specific standard in the series. With clear, concise explanations, you'll find details on:
Cross-referenced and packed with "capsule answers" for quick access, the ISO 14000 Answer Book has the information and guidance you need to get up to speed fast on this all-important series of environmental management standards.
". . . an excellent tool for professionals to gain insight into ISO 14000." —Susan Malette, Quality Manager, Digital Equipment Corporation.
"Slowly we've learned that no one can afford to treat environmental protection as a spectator sport. This book gives top corporate managers the critical information they need to make environmental protection part of their everyday operations." —Doug Costle, Former Head, US EPA.
". . . a valuable mechanism to understand the implications of specific aspects of ISO 14001 and make informed decisions." —J. Eldon Rucker, Deputy Director, American Petroleum Institute
"This book is being used by a wide variety of organizations wishing to learn more about ISO 14000 standards and their potential use worldwide." — Amy Schaffer, American Forest & Paper Association.
"The ISO 14000 Answer Book is a must for environmental and business managers seeking to improve environmental performance and gain a competitive advantage." — Paul T. Robbertz; Manager; Environmental, Health, Safety and Regulatory Services; Hampshire Chemical Corporation.
"Business leaders who want to improve their environmental stewardship and corporate citizenship will find the ISO 14000 Answer Book a valuable reference." — Andrew E. Lietz, President and CEO, Hadco Corporation.
Deciding Whether to Seek ISO 14000 Certification.
The Relationship Between International Quality Standards and Environmental Standards.
The Impact of ISO 14000 in the Marketplace and Public Arena.
Implementing an Environmental Management System Under ISO 14001.
Auditing of Environmental Management Systems.
Standards for Evaluating Environmental Performance.
Standards for Product Assessment.
Going Through the Certification Process.
ISO 14000 Standards and Health and Safety Practices.
The Legal Implications of ISO 14001.
About the Authors.
My company already complies with all applicable environmental rules and regulations. Why isn't that enough?
Compliance with regulations is basically a reactive approach to managing your company's impact on the environment. In essence, compliance focuses your attention on the impact of regulation on your business. An environmental management system (EMS), however, is a proactive approach that focuses your organization on its full impact on the environment.
When you focus only on environmental impacts that are part of formal regulatory programs, you often fail to see the full range of effects that your company may have on the environment. A regulatory approach does not necessarily produce the best environmental results, and the cost to business may be out of proportion to the associated benefits.
Command-and-control regulations have brought about a significant reduction in pollution, but the resulting bureaucracy has often taken on a life of its own and can stifle innovation.
Can you give me an example of how command-and-control regulations are inadequate?
A good example can be found in the traditional manufacturing process. A company without an EMS asks its engineering department to design a manufacturing process for a new product. The process design engineer considers many important issues, such as the cost of raw materials and the availability of fabricating equipment. Few, if any, of the issues considered relate to the environmental impact of the product or its manufacturing process.
Once the design is complete, the company's environmental manager must identify the permits that will be needed and establish a system to monitor and dispose of the hazardous wastes expected to be generated by the new manufacturing process. Regulatory agencies are consulted and a process set in motion to be able to meet ''the letter of the law.''
What is the alternative to this traditional approach?
A company with an effective EMS would be more likely to approach this new product development task differently. The process design engineer would take environmental concerns into account at all stages of the design process. He or she would consider how to use raw materials that generate a minimum of hazardous wastes or are devoid of hazardous components. He or she would look for opportunities to incorporate environmentally friendly components into the design that would facilitate disassembly, reuse, recycling, and remanufacturing at the end of the product's useful life. The total environmental impact is considerably less than under a strict command-and-control approach.
Don't all organizations focus mainly on complying with government rules and regulations?
Since the 1970s, companies have focused on the legal implications of noncompliance. In the United States, for example, the bureaucracy that has developed around environmental permitting and reporting has made environmental compliance a full-time job in many organizations.
Nonetheless, organizations are beginning to look for ways to address environmental impact in the same manner as management addresses the financial or human resources sides of their operations. A systematic approach to managing environmental impact is called an environmental management system, or EMS.
What can an EMS do that simple compliance cannot?
An EMS can provide opportunities for creative prevention of pollution. Instead of looking at only the ''end of the pipe'' solution, an EMS develops procedures to help your company minimize its overall environmental impact. This can be done through process design, employee awareness, innovative reuse or recycling, careful raw material selection, and so on.
An EMS helps you manage all aspects of your company relative to the effect on the environment.
Why should my company be brought in line with ISO environmental management standards?
ISO 14000 is a series of international standards relating to environmental management. One specific standard in this series, labeled ISO 14001, provides a good model for development of an EMS. Its development has resulted in a great deal of interest in and awareness of a systems approach to environmental management. If your organization seeks to establish a program to manage its overall environmental impact, it would do well to use ISO 14001 as a template. It's a good idea even if you may not be immediately interested in formal certification under the standard.
Due to the growing visibility and growing acceptance of the ISO 14001 standard, several driving forces are causing many companies to look seriously at adopting this standard. Whether your organization chooses to implement the standard will depend on the specific nature of your operations and the marketplace in which you conduct business. Chapter 4 discusses the impact of ISO 14001 on the marketplace.
What factors should be considered in determining the value of ISO 14001 to my organization?
Driving forces such as market demands, customer requirements, and regulatory interest are discussed elsewhere in this book. Your decision to implement ISO 14001 will be influenced by the impact of those forces on your operation. However, the decision as to whether to implement ISO 14001 should also take into account the nature of your operations and the potential benefits to be realized from better management of your environmental impact.
For example, if your organization is spending time and money dealing with environmental incidents caused by poor control of processes, inadequate record keeping, employee unawareness, or inadequate training, an analysis of the costs associated with these incidents may well demonstrate that development of a management system to reduce these incidents would save you money. This type of cost-benefit analysis should form the basis for strategic decisions regarding ISO 14001.
Will my competitors adopt ISO 14001?
Depending on the nature of your business, many of your competitors may adopt this standard. You can assume that your competitors will perform the type of cost-benefit analysis discussed in the previous paragraph. They will evaluate the impact on their own operations of market forces that are driving acceptance of ISO 14001.
Over time it will be easier to understand what forces are driving adoption of ISO 14001. You will be able to see in which market sectors adoption is most critical, in what areas of the world adoption is compulsory, and in what countries governmental acceptance of the standards has actually mandated adoption of the standards.
If ISO environmental standards are met early, can my company gain a competitive advantage?
Companies that correctly anticipate changes in the marketplace always have a competitive advantage. It isn't easy to predict what impact ISO 14001 will eventually have on business, but companies in competitive market segments should not risk being left behind.
As the use of the standard develops over time, the uncertainties surrounding its adoption decrease and decision making becomes easier. Unfortunately, by then, any hope of gaining a competitive advantage is gone.
Naturally, if you can realize cost savings through implementation of ISO 14001, those cost savings could be passed on to your customers. These savings can give you a competitive advantage on cost even in a market where customers have no knowledge of ISO 14001 and have no interest in requiring suppliers to certify to the standard.
Will my company need to meet ISO 14001 standards if I am not involved in international sales?
Just because you are not directly involved in international sales does not mean that you can ignore the new ISO environmental management standards. ISO standards are not new, and by looking at the manner in which other standards have gained acceptance, we can predict what road ISO 14000 will likely travel. Particular precedent can be found in the recent adoption of international total quality management standards, known as ISO 9000. The track record of the quality standards indicates that there will be numerous ways in which ISO 14001 will be passed down through multiple tiers of suppliers locally and globally.
How will suppliers be affected by the ISO 14001 standards?
Automobile manufacturers and manufacturers of electronic consumer goods, for example, have required suppliers of component parts to certify to ISO 9000 quality standards. Therefore, it is certainly possible that large manufacturers who implement ISO 14001 environmental standards may also require that their suppliers demonstrate compliance with ISO 14001.
If you sell products to large retail chains, you may also need to demonstrate compliance with the standards. Given the mobility of today's societies and the global movement of goods and services, it has become difficult to determine whether a product will or will not enter the international market or be influenced by market conditions.
The Relationship Between Government Regulation and Voluntary Standards
What do government regulators think about ISO 14001?
In the United States, state and federal regulators are showing increasing interest in the concept of EMSs and, specifically, in ISO 14001. The major concern voiced by regulators is that ISO 14001 only develops a systematic approach to environmental issues and does not set performance standards. The extent to which ISO 14001 results in improved environmental performance is dependent on the manner in which it is implemented and maintained. Despite this perceived flaw, regulators are showing interest in the benefits of proactive environmental management.
The approach taken by some regulators has been to develop their own version of ISO 14001. Essentially, this approach requires organizations to have ISO 14001 in place, as well as an additional program that includes environmental performance standards.
In the United States, what advantages will ISO 14001 provide my organization when dealing with state and federal regulators?
ISO 14001 certification alone is unlikely to provide the level of assurance required by state and federal regulators.
Nonetheless, regulators are looking at ISO 14001 certification as part of an overall environmental compliance program. An EMS can be used to demonstrate an effective compliance history or a good faith effort to comply. This could potentially lead to less frequent monitoring and reporting requirements, reduced or expedited permitting requirements, and less frequent inspections.
Environmental Protection Agency (EPA) programs incorporating or considering ISO 14001 have included the EPA-New England Third Party Certification (StarTrack) Project, and the EPA Headquarters' sponsored Project XL, Environmental Leadership Project, and other media-specific programs. Chapter 11 discusses the use of ISO 14001 by governmental bodies in more detail.
Are there other regulatory advantages to implementing ISO 14001 in my organization?
Under several enforcement and penalty mitigation policies in the United States, a properly implemented and maintained ISO 14001 program could become the basis for significant reductions in civil and criminal penalties. Examples include the EPA Auditing Policy, the Department of Justice Guidance for Prosecutors, and the U.S. Sentencing Commission Guidelines. The issue of regulatory benefits and penalty mitigation for companies using ISO 14001 is discussed at greater length in Chapter 11.
Will command-and-control type regulations become obsolete?
Command-and-control regulations are not expected to disappear in the foreseeable future. Before regulators will loosen their control, a significant amount of data will be required to demonstrate that a properly implemented ISO 14001 program produces results. The data will have to show that there is improved environmental performance, that regulators can effectively monitor ISO 14001 performance, and that organizations are seriously interested in managing their environmental performance.
Regulators will probably always maintain some control, but companies will be given the freedom to be more creative in the management of their environmental impact.
What do environmental groups think about ISO 14001?
Unfortunately, initial reaction of nongovernmental organizations in the environmental field has been less than enthusiastic. Similar to government regulators, they mistrust standards that do not set a level of environmental performance. In the United States, many environmental groups have been reluctant to take an overly active role in the development of the ISO 14000 standards. They have been concerned that participation would result in perceived acceptance of the standards.
Can ISO 14001 help my company limit its environmental liability?
Yes, it has that potential. The standards provide an opportunity to respond more efficiently and proactively to your operation's environmental impact. Likewise, adoption of ISO 14001 has the benefit of raising employee awareness of environmental impacts, it helps your company better track environmental issues, and it provides for creative planning in pollution prevention efforts.
Some state and federal programs already exist in the United States to provide credit for organizations with an EMS in place. These credits- in the form of reduced fines and penalties, reduced oversight, or priority review-can result in significant cost savings. The trend is clearly toward more acceptance of ISO 14001, translating into new opportunities for regulatory-related cost savings, although the degree to which this acceptance becomes widespread is still an evolving issue. See Pennsylvania's policy in Appendix D.
Understanding Environmental Management Systems
What is an EMS?
In simplest terms, an EMS is a systematic approach to dealing with the environmental aspects of a business or other organization. It is not something new or unique. Many organizations have had many of the components that make up an EMS in place for years. In the United States, environmental regulations have required companies to develop many parts of an EMS in one form or another. These regulations include development of operational procedures, training, audits, corrective action, and emergency preparedness.
How does an EMS function?
An EMS brings together many separate elements, placing them in a framework. The coordination of these components provides companies with a systematic way to understand and control the many elements of environmental management. An important part of an EMS is its ability to track how the various parts of the system are functioning. This allows management to make corrections and take action necessary to prevent future problems.
An EMS is often implemented across an entire organization, but may also be adopted in each division or at each plant.
What are the basic elements of an EMS?
An EMS can be broken down into six parts: * Understanding of your organization's environmental impact and requirements.
* Reviewing your organization's existing operations and procedures.
* Working to develop an EMS.
* Training of employees.
* Monitoring of your organization's overall performance.
* Reviewing performance and taking corrective action.
What is the difference between an EMS and a governmental regulation?
An EMS does not set performance requirements; that is, it does not require that air emissions, for example, be held below a certain numerical level, nor does it prescribe limits for wastewater discharges. An EMS sets up a management system that ensures that certain activities are undertaken, at the correct times or frequency, and that those activities are documented and reviewed.
An EMS reflects the goals and objectives of a particular company, customized to the needs of that organization. An EMS achieves environmental improvement through better management of those activities that affect the environment.
What EMS standards exist other than ISO 14001?
ISO 14001 was developed during a time when many national standards and some international standards were either under development or already in use. A British standard, BS7750, was published in early 1992. It was pilot tested in the United Kingdom and revised in early 1994.
In late 1994, the European Union, through the European Commission, adopted the Eco-Management and Audit Regulation. This regulation included the Eco-Management and Audit Scheme (EMAS), which established EMS specifications for organizations doing business in the European Union.
Organizations throughout the world, including some in the United States, adopted the British BS7750 standards, the European Union's EMAS standards, or both. Much of the original draft language in ISO 14001 was influenced by BS7750, in particular, as well as other national standards.
How will ISO 14001 interact with Britain's BS7750?
Upon finalization and publication of ISO 14001-and British acceptance of it as a national standard-BS7750 became obsolete. Companies registered to BS7750 now are considered to be registered to ISO 14001.
How does ISO 14001 relate to the European Union's EMAS?
EMAS has requirements that are not included in ISO 14001. Therefore, organizations certified to ISO 14001 must demonstrate compliance with some additional requirements before they will be in compliance with the EMAS standards. These additional requirements are set forth in a document meant to bridge the two standards. A useful comparison of ISO 14001, EMAS, and ISO 9000 is included in the ISO 14000 Resource Directory, Appendix A.
Will my organization need to meet multiple EMS standards?
The ISO 14001 Approach to Environmental Management Systems
What does ISO stand for?
ISO is the name given the International Organization for Standardization, a global federation of 118 countries headquartered in Geneva, Switzerland. The name is not a modification of an acronym for the organization's name, but was selected because in Greek isos means equal, representing the organization's goal of global standardization. The organization was formed in 1947 to promote the development of international standards. Over the years, the organization has developed standards ranging from photography (film speed coding) to banking (ATM communications). Appendix C provides a list of ISO member countries.
What group represents each country in the development of standards?
The type of national representation varies between countries. In many countries, government agencies administer all national standards, including ISO 14000. At the other end of the spectrum are countries in which national standards development or approval is handled completely within the private sector. Between these extremes one finds numerous variations including quasigovernmental boards, closely regulated private sector organizations, ministries, and so on.
In the United States, the national standards process is a private sector function without government sanction. As discussed later, the American National Standards Institute (ANSI) is the U.S. member body to ISO, and the American Society for Testing Materials (ASTM) is the U.S. administrator. Bodies such as ANSI and ASTM are private sector organizations whose membership is primarily composed of companies working within the areas to which the standards apply.
How does ISO go about developing standards?
ISO solicits input from member countries, government bodies, industry, and other interested parties to evaluate the need for an international standard. The need for standards is also evaluated in light of the organization's goal of seeking to facilitate the international exchange of goods and services and to develop cooperation in intellectual, scientific, technological, and economic activity.
Are ISO standards mandatory?
No, ISO standards are totally voluntary and carry no legal requirements. Member countries are not required to adopt or even support final standards. However, standards are developed through a consensus-building process so that the resulting standards are acceptable to the majority of member countries. This participation of member countries in development of the standards normally translates into wide international acceptance of the standards.
Individual countries, as well as industrial groups, often adopt ISO standards as national standards or industry practice standards. In these circumstances, the standards become de facto requirements.
Are ISO standards typically related to the environment?
ISO standards have been developed for many specific activities and are typically technical in nature. With more than 210 technical committees, the environmental arena is only one subset of the many ISO standards.
ISO standards have not typically centered on management systems. The first ISO standard developed as a management system was ISO 9000, the international standard for quality management. (See Chapter 3 for a discussion of the similarities between ISO 9000 and ISO 14000.) ISO 14000 is another effort by ISO to develop a management system standard.
How did ISO decide to develop EMS standards?
In June 1992, an international conference was held in Rio de Janeiro, Brazil, out of which came the Rio Declaration on Environment and Development. The concept of sustainable development, development that is sensitive to its impact on energy use and the environment, was at the core of the 27 environmental guiding principles presented in the declaration.
Based on the outcome of that conference, the Strategic Advisory Group on the Environment (SAGE) was charged with studying the need for, and potential structure of, international standards for environmental management that would address the concerns raised at the conference. SAGE formed six subcommittees to review different aspects of EMSs.
What were the six areas reviewed by SAGE?
SAGE examined the following areas:
Environmental management systems
Environmental performance evaluation
Life cycle analysis
Terms and definitions
How did ISO become involved?
In June 1993, based on SAGE recommendations, ISO organized an international technical committee, Technical Committee 207, referred to as TC 207, to begin the process of drafting international standards.
How is TC 207 organized?
The scope of TC 207-''standardization in the field of environmental management tools and systems''-was simple in concept, but difficult to implement. Using the same structure developed by SAGE, TC 207 set up six international subcommittees:
SC 1 Environmental management systems (ISO 14001/14004)
SC 2 Environmental auditing (ISO 14010, 14011, 14012)
SC 3 Environmental labeling (ISO 14020 series)
SC 4 Environmental performance evaluation (ISO 14030 series)
SC 5 Life cycle analysis (ISO 14040 series)
SC 6 Terms and definitions (ISO 14050 series)
Each subcommittee is comprised of representatives from many of the ISO member countries. The role of each subcommittee is to develop a portion of the draft standards for review and approval by the entire technical committee and ultimately by all ISO member countries.
As of November 1996, there were 51 participating countries, 17 observer countries, and 25 liaison organizations involved in ISO 14000 standards development. Participation varies from one subcommittee to another. Member countries involved in TC 207 are provided in Appendix C.
Is ISO focusing on the environment beyond the 14000 series of standards?
Another working group, the Environmental Aspects in Product Standards committee, was also established to develop guidelines for standards writers in other areas. The purpose of these guidelines is to ensure that standards developed for other product areas also consider the environmental implications of the activities addressed by that standard.
What is a liaison organization, and what is its role in the process?
By petitioning ISO, organizations may request liaison status on a technical committee or subcommittee. The guidelines to receive liaison status are relatively simple. They require that an organization be non-profit and international in scope. The organization must also have an interest in the subject matter or be able to contribute to the development or acceptance of a standard.
Liaison organizations receive all working documents, may attend meetings, and may submit written comments on draft standards. Although a liaison organization may vote in working groups, it does not have a vote at the subcommittee or technical committee level.
Liaison status has allowed environmental groups to take stands that are at odds with consensus positions presented by the body representing a group's home country.
How does ISO go about developing individual standards?
When TC 207 was first organized, each subcommittee proposed a work plan and submitted it for approval by the larger committee. Any new area in which a subcommittee would like to work must be approved by the technical committee.
These so-called work items have typically resulted in the formation of working groups within the subcommittee. For example, Subcommittee 1 developed ISO 14001 (the specification standard) in Working Group 1.
How did the actual ISO standards start to take shape?
Once each subcommittee was organized, members produced working drafts (WDs). The number of WDs developed within a subcommittee or working group (WG) varied with the complexity of the specific standard being written. When ready, the subcommittee votes whether to elevate the WD to the status of a committee draft (CD).
A CD then goes through a 3-month period where comments and proposed changes are drawn up by subcommittee members. After further revision, the subcommittee may vote to raise the CD to the level of a draft international standard (DIS). The DIS must undergo a 6-month period of review by ISO members.
If reviewed favorably, the draft standard, with minor editorial changes as needed, is reissued as a final draft international standard (FDIS). ISO members then have 2 months to vote ''yes'' or ''no.'' If approved, the final standard is then published.
How has the United States developed its position on the ISO 14000 standards?
ANSI represents U.S. interests as the country's ISO member. A technical advisory group (TAG) was formed by ANSI to develop the actual U.S. position.
Six subcommittees, or Subtags, were then established, organized in the same manner as the subcommittees of the international TC 207. ASTM, an ANSI member, was given the task of administering the U.S. TAG.
How have the U.S. subcommittees, or Subtags, functioned?
Each U.S. Subtag develops positions, reached by consensus, in a series of meetings with members of that Subtag. The chairman, elected by Subtag members, runs the meetings and is head of the delegation to international subcommittee meetings. Drafts developed at the international subcommittee meetings are reviewed and edited by the U.S. Subtag, and new language is developed for submission to the international subcommittee. Official U.S. comments on international subcommittee WDs or CDs are prepared by the U.S. Subtags.
On a broader level, a chairman's advisory group (CAG) was established. It is chaired by the chairman of the U.S. TAG and includes each Subtag chairman and others appointed by the chair. Meetings of the CAG, as well as TAG meetings themselves, provide forums in which overall U.S. positions can be discussed and debated. The CAG helps maintain consistency on positions in all U.S. Subtags.
Who can become a member of the U.S. TAG?
The TAG and all Subtags have been open to any representative of a U.S. organization upon payment of an annual administrative fee. This has enabled anyone interested in the development of the standards to participate. There are 500 members of the U.S. TAG.
Members to the TAG include representatives from trade and professional organizations, government agencies, companies, environmental consulting firms, and environmental groups. U.S. TAG members may be actively involved in one or more Subtags or may act just in a notification and review capacity. All TAG members vote on drafts from the various international subcommittees. The table on page 19 illustrates the diversity of membership distribution.
Who presents the United States' position at the international level?
Experts present each country's position at international subcommittee meetings. The number of experts is established by each subcommittee, but generally has been limited to two experts per working group plus the head of the country's delegation. U.S. Subtags normally vote on which experts will represent them at the international subcommittee meetings.
What is the status of the ISO 14000 standards?
The following standards were elevated to DIS status in late 1995 and were approved and published as international standards in late 1996:
ISO 14001 Environmental management systems-Specification with guidance for use
U.S. TAG Membership Distribution
As of 1996, the U.S. TAG had 510 individual members representing 423 different organizations. The distribution of individual members was as follows:
28 Electrical machinery/electronics
7 Primary metals
10 Transportation equipment
3 Fabricated metals
5 Machinery (except electrical)
1 Instruments/measuring or controlling
23 Other (glass, consumer products, automobile)
25 Potential registrars/auditors
8 Engineering and construction
5 Media/public relations
61 Other (academia, government, nonprofit environmental)
ISO 14004 Environmental management systems-General guide-lines on principles, systems, and supporting techniques
ISO 14010 Guidelines for environmental auditing-General principles
ISO 14011 Guidelines for general auditing-Audit procedures- Auditing of environmental management systems
ISO 14012 Guidelines for general auditing-Qualification criteria for environmental auditors
Work on standards for environmental labeling, environmental performance evaluation, and life cycle assessment continues as discussed in Chapter 12.
What happens after ISO standards are issued?
ISO does not implement standards. This is left to the organizations themselves, although trade associations, national standards organizations, governmental agencies, and consultants may provide varying levels of assistance in interpreting and implementing ISO standards.
ISO standards undergo 5-year reviews, and modifications, edits, or corrections may be made at that time based on the experience of those who have put the standard into practice. For ISO 14000 standards, it is anticipated that the technical committee will continue functioning for many years. This will give it time to complete remaining standards, to ensure the continued viability of the final standards, and to handle proposals for related standards in this field.
The U.S. TAG likewise will continue for the same purposes. In addition, a committee of U.S. TAG members has been formed to assist in interpreting the final standards.