Drafting the future of EMS
Sarah-Jayne Russell talks to IEMA members about the proposals for the next incarnation of the EMS standard
ISO 14001, the international systems standard for environment management, has stood at the heart of organisations’ efforts to understand and reduce their impacts on the natural world for nearly two decades. More than 250,000 certificates have been issued globally, and they are held by organisations as diverse as multinational oil producers, local waste collectors and individual sports venues.
The current standard has been in circulation since 2004, during which time attitudes to sustainability have undergone a sea change, as organisations have become increasingly aware of the need to better manage the world’s natural resources and protect themselves from the impacts of climate change. While political ambition to tackle international carbon emissions has been buffeted by the ongoing financial crisis, companies such as Marks & Spencer, Puma and Unilever have openly re-evaluated their business models in light of sustainability challenges.
It is against this background that ISO – the international standards organisation – began, in 2012, the journey to revise and revitalise 14001. Following more than a year of work, ISO published a committee draft of the new edition of the standard in April. Practitioners were asked to give their feedback on the new structure and content of the proposed standard. Potential amendments will be discussed at an ISO working group meeting at the end of June.
New look
The most obvious change between the current version of 14001 and the committee draft is its structure. The environment management standard is the first be redrafted in line with ISO’s new high-level structure, which it is rolling out across all its standards.
“There are significant changes to the way 14001 looks,” confirms Kirsten Holman, MIEMA, company environmental manager (UK) at engineering consultancy Parsons Brinckerhoff. “Some people at the IEMA workshop I attended were quite taken aback by the difference, but I think the high-level structure is easy to understand and it will be beneficial in supporting integrated management systems.”
Toby Robins, AIEMA, sustainable development director at office supply company Wiles Greenworld, agrees: “It’s particularly important for 14001 to be aligned with other standards because it helps to embed good environmental practice alongside health, safety and quality, and ensure that environment targets are acted upon rather than being seen as an aside.”
Marek Bidwell, MIEMA CEnv, director of environmental training firm and consultancy Bidwell Management Systems, says the new layout will be more familiar to those who have worked with quality management systems. “The new structure is very similar to ISO 9001 [the quality standard], with the section dealing with leadership towards the start of the standard, for example. The changes might make some environment management people pause, but actually the order of the clauses is much less important than what the clauses say.”
More than skin deep
The changes to the standard go a lot further than rearranging its contents, however, with expansions to the definition of environment policy, as well as new requirements concerned with organisational strategy, the role of leaders, life-cycle impacts and supply chains.
Anya Ledwith, MIEMA CEnv, director at environment and carbon consultancy ESHCon, says the most exciting changes to the standard are the requirements under the leadership section for organisations to integrate the requirements of the environment management system (EMS) into their core business practices and to consider environmental performance in strategic planning.
“I see a lot of companies using 14001 because it’s a compliance issue and, while the EMS might work really well, it’s slightly sidelined. The environment manager has to knock very loudly on the door of the managing director, rather than them being invited in,” she says. “The new requirements will help to combat this, and to cement the role of an EMS in the organisation. I think it will ensure that the work of environment managers is recognised more strongly.”
Holman agrees: “There seems to be a lot more emphasis on top management being involved, which is a really good thing. I am physically remote from our chief operating officer and senior management team, and I want them to get more involved in the running of the EMS. The changes give a lot more definition about the role of leaders and I can go back to my senior managers and say we need to put in more resources and commitment to meet these requirements. It will mean that 14001 is a more useful tool for me to get buy-in.”
Ben Vivian, FIEMA, director of consultancy firm Vivian Partnership, however, asks whether ISO may need to clarify the text, confirming that it means strategic planning for the whole organisation, or risk some users creating separate strategic plans for the EMS.
“By not explicitly stating that this is about organisational strategic planning, the standard’s writers may have created a loophole where people could say ‘we’ve interpreted this as environmental strategic planning’, whereas the intent was a much broader organisational definition,” he says.
David Symons, MIEMA CEnv, director at WSP Environment and Energy, meanwhile, argues that the strategic element of the proposed standard could be stronger. “Most systems are really strong on considering how the firm impacts the environment, but generally are much weaker on considering how issues like climate change, resource prices and societal demand will impact on them. These external impacts are the really key issues for strategic planning,” he comments.
However, this is where the new concept of “environmental conditions” will help, according to Vivian. Alongside environmental aspects, the revision introduces the term “environmental condition”, which it defines as “long-term environmental changes that can affect the organisation’s activities, products and services, requiring adaptation”.
“This should start getting organisations to think about the environment’s impact on them, rather than the impact they have on the environment, which is a significant weakness of how the current version of 14001 is being implemented. You can interpret it to consider these things, but it’s not a natural fit,” Vivian argues.
While welcoming ISO’s attempt to incorporate adaptation into 14001, he warns that it appears in the draft to sit slightly away from the rest of the system. “It seems to me that you could interpret the adaptation side of things as a being almost a parallel process from the main EMS. The way that it is woven into the rest of the requirements for the standard needs to be given careful consideration,” Vivian says.
He also suggests that the standard should highlight the differences in approach needed to reviewing environmental conditions compared with environmental aspects. “Because operational matters change reasonably frequently, reviewing aspects at least once a year is a good thing. Conditions, however, are large-scale, long-term issues, such as climate change or access to land, and the new standard needs to be clear that reviews will be a lot less frequent.”
Value chains
Another significant change in the proposed revision to 14001 is the broadening of the scope of the EMS to consider environmental impacts throughout organisations’ value chains. The draft standard states that users should identify environmental aspects that it can control and “those it can influence considering a life-cycle perspective”.
Such an approach provides organisations with the opportunity to think about environment management not only as risk control, but also to consider the value it can add to their businesses, according to Bidwell. “Increasingly, there seems to be a dual stream approach to environment and sustainability management, with traditional environment managers thinking about pollution prevention, while other companies are changing their business plan to align themselves with issues like sustainable resource use.
“By talking more about the life cycle of a product or service, 14001 is now catching up with best practice in terms of sustainability. Sometimes the environmental implications of products are not immediately apparent to companies. For example, a sheetmetal manufacturer might not realise the influence it can have on a client’s technical plans to use less material. If environmental issues are embedded in the product design process and considered across the life cycle, this can be of real value to clients,” Bidwell argues.
The draft standard also includes a new clause on managing environmental aspects throughout value chains. It states that certified organisations must ensure that all processes related to significant aspects, both “upstream and downstream” the value chain, are “controlled or influenced”.
“Making it explicit that systems should consider impacts outside of direct operations is an important one,” says Symons. “But it would be stronger if there was more balance in the text between buying decisions and products in use. At the moment, while there is plenty of text on buying decisions, product impacts get only a handful of words – in spite of this being most firms’ largest impact.”
Meanwhile, Holman believes that the draft text on value chains could be improved. “There’s a small piece of text on the value chain, which is followed by four explanatory notes. I think it needs to be more concise and clearer about what’s expected from organisations,” she says.
“My company has more than 1,200 suppliers and subcontractors and has projects all over the world. While we already assess all our suppliers before we work with them, if we have to apply a full life-cycle approach it would be difficult.”
In contrast to Holman, who suggests more guidance is needed, Ledwith argues that it is best that the final standard avoids being too prescriptive. “Standards have to be quite top level, so each individual organisation can decide how it applies to them,” she says. “If ISO writes it down in black and white, something might be relevant to one company and not another.”
Ledwith comments that it will take some time for organisations to really get to grips with this part of the new standard. “There’s going to be an element of people asking what they should be doing. Only once the standard has been adopted and audited against will we find those case studies on what’s good and how far down the supply chain people should be going.”
Environmental performance
One of the criticisms frequently levelled at the current version of 14001 is that the standard does not necessarily drive improvements in the environmental performance of its users, with assessment focused on evaluating whether an effective EMS is in place. Robins at Wiles Greenworld believes that the standard’s writers have gone some way to help tackle this issue in the proposed draft.
The “continual improvement” clause in the revised standard states: “[Users] shall continually improve the suitability, adequacy and effectiveness of the EMS, to enhance its environmental performance as set by top management in line with the environmental policy.”
“On first reading this I was concerned that environmental performance was being defined as measuring impact and not when mitigating it,” says Robins. “That was until I went back and reread the clause on environmental policy, which emphasises more strongly commitments to pollution prevention and environmental protection.
“A huge amount of thought has gone into this standard and how it all links together. There is a stronger emphasis on the requirement for continuous improvement, in line with the policy set by top management, so hopefully there’s less room for misinterpretation,” says Robins.
He does, however, acknowledge that much of potential benefit in this shift of emphasis is reliant on how auditors assess against the standard.
Other changes, including the move to make an EMS more strategic and the consideration of environmental conditions, are equally dependent on how the standard is audited, according to Vivian, and may pose a considerable challenge for assessors.
“The ability for an auditor to interpret how users are strategically managing adaptation to environmental conditions is both important and technical,” he says. “I’ve asked a lot of people about how they would do it and none have much of a clue; it’s a tough thing to do.”
Vivian believes a further benefit of the proposed new standard is that it talks about the EMS as a whole. “It leads the organisation to decide where in the EMS the management of significant aspects best sits for them, rather than directing people to do it under certain aspects, such as training or operational control.”
However, this creates a complication for those certifying the EMS, he says, particularly if they have expectations of where certain issues should be managed in a system. “Some certification auditors will have to be more imaginative about how they assess organisations, considering the effectiveness of the approach of the EMS for the company. This means that the audit process is likely to be less formulaic and will have a greater degree of subjectivity.
Opportunity knocks
Overall reactions to the committee draft of the standard are positive, with IEMA members agreeing that the changes have strengthened the standard and its ability to be embedded in organisations.
“The new edition of the standard will be much more of a challenge for firms, even those that have held 14001 certification for a long time,” says Ledwith. “But the changes are an exciting opportunity that will help to integrate an EMS into an organisation.”
Holman says: “There’s going to be change, but that change is needed. People are worried about how to demonstrate meeting some of the new requirements to auditors, but with some clarifications to the text I think those concerns will be eased.”
The next meeting of the ISO working group revising 14001 will take place in Botswana at the end of June 2013, and will discuss reactions to the committee draft from across the world. All potential amendments will be examined and a second committee draft is expected to be published later in the year. ISO member states will then be balloted. The final standard is due to be published in 2015.