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Tools for Monitoring Environmental Health1

Environmental management systems (EMSs) are tools that corporations and some government agencies use to manage environmental issues. These systems may vary from facility (or agency) to facility but the basic premise is to implement the broader concept of sound and proactive environmental management. In recent years, EMSs have evolved further to respond to increasing stakeholder pressure to improve social responsibility. As more companies, federal agencies, and organizations choose to implement EMSs, such as that established by the International Standards Organization (ISO) and known as ISO 14001, it is important to consider the current state of the research concerning the relative successes and obstacles associated with existing systems in what impact it will have, if any, on environmental health. This chapter gives an overview of EMSs, their characteristics, focuses, and benefits.

ENVIRONMENTAL MANAGEMENT SYSTEMS

The environmental management concept, using the EMS as the platform, is a highly productive strategy to achieve sustainable environmental stewardship promotion throughout the federal community, said Edwin Pinero, Federal Environmental Executive. EMS provides a structured, systematic approach to negotiate environmental issues and have two key components: integration of management of environmental issues in daily operations and improvement-oriented practices. EMSs seek to bridge the gap between the environmental and business or operational sides of an organization. According to Pinero, the basic components of an EMS include:

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The views expressed here do not necessarily reflect the views of the Institute of Medicine, the Roundtable, or its sponsors. This chapter was prepared by Jenners Foe-Parker from the transcript of the meeting. The discussions were edited and organized around major themes to provide a more readable summary and to eliminate duplication of topics.



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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary 1 Tools for Monitoring Environmental Health1 Environmental management systems (EMSs) are tools that corporations and some government agencies use to manage environmental issues. These systems may vary from facility (or agency) to facility but the basic premise is to implement the broader concept of sound and proactive environmental management. In recent years, EMSs have evolved further to respond to increasing stakeholder pressure to improve social responsibility. As more companies, federal agencies, and organizations choose to implement EMSs, such as that established by the International Standards Organization (ISO) and known as ISO 14001, it is important to consider the current state of the research concerning the relative successes and obstacles associated with existing systems in what impact it will have, if any, on environmental health. This chapter gives an overview of EMSs, their characteristics, focuses, and benefits. ENVIRONMENTAL MANAGEMENT SYSTEMS The environmental management concept, using the EMS as the platform, is a highly productive strategy to achieve sustainable environmental stewardship promotion throughout the federal community, said Edwin Pinero, Federal Environmental Executive. EMS provides a structured, systematic approach to negotiate environmental issues and have two key components: integration of management of environmental issues in daily operations and improvement-oriented practices. EMSs seek to bridge the gap between the environmental and business or operational sides of an organization. According to Pinero, the basic components of an EMS include: 1 The views expressed here do not necessarily reflect the views of the Institute of Medicine, the Roundtable, or its sponsors. This chapter was prepared by Jenners Foe-Parker from the transcript of the meeting. The discussions were edited and organized around major themes to provide a more readable summary and to eliminate duplication of topics.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary A policy Identification and prioritization of environmental attributes (aspects and impacts) Goals or objectives or targets Implementation plans, milestones, and timelines to meet goals Definitions of roles and responsibilities Training and competency needs of workforce Operational controls and work procedures to manage environmental attributes Communications procedures and document controls Emergency planning and response Monitoring and measurement, that includes regulatory compliance and EMS auditing, and corrective action mechanisms Senior management reviews leading to continual improvement While these basic components define a framework, environmental management is a broader term that also encompasses the organization’s overall culture, commitment, and approach to achieve performance goal, said Pinero. For this to happen, management needs to identify the appropriate measurements to achieve goals and, at the same time, ensure that the organizational culture, leadership, and corporation’s mission and operation are in step with environmental management. The management system model is built on the premise that senior management is consistently participating or otherwise involved in management system implementation. The role of management is critical, not only for the specific responsibility of providing resources and accountability, but also for providing the leadership message and the commitment to stewardship. There are key points where senior management has a defined role and where their ongoing support is critical; for example, organization’s policy, management review, the mission, vision, and support for improved environmental procedures, noted Pinero. However, understanding why procedures are performed will produce more responsible action in the future, because the individual will appreciate the implications of their actions. Thus at all organizational levels, individuals must share the commitment to achieve company goals for sustainable environmental practices. Best Practices Despite wide implementation of the overall framework, EMSs are quite varied across organizations, noted Pinero. They vary in their content, coverage, and spectrum. In general, an effective EMS has three characteristics that lead to the benefits of sustainable practices. First, an EMS directs and facilitates relevant

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary measurements to analyze information for environmental improvement. Measurements can include environmental conditions, status of programs, compliance, and the EMS itself. Interestingly, this very point of using appropriate measurements as a management tool poses a new challenge as Executive Order 13148 goes into practice in 2006, noted Pinero. The order required the federal community to have EMSs in place by the end of 2005. As the agencies begin to implement their EMSs, the task at hand will be to measure how environmental management systems help improve agency performance rather than simply measuring progress of implementing the system. Second, an efficient EMS focuses on measuring the aspects of, rather than the impact of, a company’s environmental interaction. An EMS is built around the capacity to identify, prioritize, control, and improve upon elements of the organization that interact with the environment. Policies that promote prevention, rather than reaction, are integral to sustaining limited resources. Third, a successful EMS utilizes a corrective action process by understanding and solving root causes. An EMS is designed to first identify the root causes of nonconformance and then initiate corrective and preventive action. In this regard, the EMS seeks to solve, rather than to control, existing environmental problems. If we do not drill down into the systemic reason for a problem, we are only treating the surface of the wound and applying bandages to the same problem over and over again, said Pinero. EMSs have both operational and general benefits, remarked Pinero. EMSs can be used to improve the organization at large by facilitating the achievement of mission goals by systematically and operationally capturing environmental issues. In addition to increasing the awareness of impacts, consistency in operations, and promoting a more effective corrective action when problems occur, successful EMSs ultimately improve the condition of the surrounding environment. A compliance management system embedded within the broader EMS addresses compliance. Compliance is demonstrated throughout the plan-do-check-act elements of an EMS, including periodic compliance audits that continually manage the management system in place. Environmental management systems in both the federal and private sectors can be proactive mediums to achieve sustainable environmental stewardship. —Edwin Pinero EMSs in both the federal and private sectors can be proactive mediums to achieve sustainable environmental stewardship. After 10 years of EMS applications throughout the world, there is hard data illustrating that every one of these benefits can be realized by a properly developed, implemented, and maintained EMS, concluded Pinero.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary ENVIRONMENTAL MANAGEMENT SYSTEMS IN PRACTICE Although the benefits of EMSs suggest improved performance, researchers are beginning to understand where, when, and how improvements are achieved. Deanna Matthews, of Carnegie Mellon University, has conducted research concerning the link between EMSs and improvement in environmental performance. Within a firm, the EMS and related information systems provide information on the status and progress of environmental activities. Decision makers use this information to change operations and technology to improve environmental performance. External to a firm, one can judge environmental performance by examining publicly reported data. Trends in these data guide policy makers to develop regulations regarding the use of EMS (Figure 1-1). One aspect of her research concentrates on the internal information flow and operations within firms. In general, she found that there is a lack of information flow from EMS departments to leadership positions, which led Matthews to question the probability of significant environmental performance improvement within each corporation. The second aspect of Matthews’ research examined the relationship between facility performance and EMSs using several different environmental perfor- FIGURE 1-1 Overview of research. EMS and regulatory compliance are related and influenced by multiple factors. This figure illustrates the interrelation between different factors. SOURCE: Matthews, unpublished.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary mance metrics—toxic release inventory releases, hazardous wastes, air emissions, and compliance history—to analyze facility performance in approximately 50 U.S. automobile assembly facilities. Overall, the results demonstrated little difference in performance between firms with and without ISO 14001 certification. This was irrespective of the length of certification or the date each company was certified. Matthews examined regulatory compliance results to measure how EMSs and compliance relate. The study examined compliance, enforcement actions, violations, and inspections within three separate, 2-year periods (Table 1-1). The inspection rate was consistent across time. From 1996 to 1998, none of these facilities had any type of EMS certified; from 1998 to 2000, the facilities with a certified EMS had a much higher occurrence of noncompliance violations. Matthews suggested that typical regulation issues were pushed to the wayside as secondarily important to the new management systems, as management was preoccupied with implementing and operating under a compliance management system. An alternative perspective is that via EMS implementation, additional regulatory issues are uncovered or that better recordkeeping identifies issues more readily. From 2001 to 2003, as all facilities in the sample are operating under EMS, over half the facilities have a significant non-compliance event, compared to only one-third of facilities prior to implementing such a system. She suggests that the compliance record indicates that the existing environmental management system is not sufficient to ensure regulatory compliance. Matthews’ studies led to five conclusions: (1) EMS components typically relate to regulatory requirements; (2) environmental information is rarely widely disseminated internally, to decision makers; (3) EMSs have low value for communicating with stakeholders; (4) the data does not support improved environmental performance, and (5) available data suggests that while ISO 14001-certified facilities may understand and manage impacts better, they may not have better operations. Lessons Learned Successful management systems support decision makers to evaluate and select projects based upon an organization’s goals, and to reduce liability or risk to the organization. They also support the general goals of a successful management system through proactive and cost-effective methods to improve operations to achieve better overall performance, said Matthews. As a result of the preceding studies, Matthews developed the following five elements for cost-effective and lasting EMSs: Develop process diagrams to identify material and energy inputs and outputs.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary TABLE 1-1 Compliance, Enforcement, and Violations from 1996–2003 as EMS Are Implemented   1996–1998 1998–2000 2001–2003 No EMS Certified EMS Certified No EMS Certified Existing Certified EMS EMS Certified Total number of facilities 50 22 28 30 20 Facilities that have been inspected 46 20 26 26 17 Percent of facilities inspected 92% 91% 93% 87% 85% Facilities w/violation or noncompliance event 38 20 19 23 16 Percent w/violation or noncompliance event 76% 91% 68% 77% 80% Quarterly periods w/1 or more violation or noncompliance event 240 115 112 159 96 Average quarterly periods with violation or noncompliance event per facility 6 6 6 7 6 Facilities w/significant noncompliance 13 4 1 12 10 Percent w/significant noncompliance event 34% 20% 5% 52% 63% Facilities where enforcement actions taken 9 9 3 18 5 Number of facilities assessed penalties 4 5 1 17 5 Total penalties assessed ($million) 0.144 0.490 0.056 1.650 0.176 Total number of enforcement actions taken 15 14 5 24 6 Average enforcement actions taken per facility 1.7 1.6 1.7 1.3 1.2 Percent of facilities where enforcement actions taken 18% 41% 11% 60% 25% NOTE: Between 2001 to 2003, there is differentiation between firms that have been operating under an ISO 14001 EMS for a few years, and those that are just getting certified. In that period of time, 80 percent violation or non-compliance was observed at the facilities going through compliance. The compliance record indicates that the existing environmental management systems were not effective processes to ensure regulatory compliance. SOURCE: Matthews, unpublished.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary Quantify goals for short- and long-term performance consistent with the organization strategic plan. Have reliable methods for collecting and disseminating environmental information to leadership and decision makers within a corporation. Use risk assessment tools for emerging environmental risks and their potential impacts. Collaboration and education for environmental professions both within and external to the firm could lead to integrated and committed environmental systems. Matthews suggested that some of the most effective lessons of the companies in her case studies came from rotating the environmental personnel from one facility to another to collaborate, check, and audit internally. Promise for the Future The regulatory-based nature of EMSs suggests that they have limited potential to reach beyond compliance. However, as EMSs and ISO 14001 evolve as tools for corporate-based management of environmental issues, they hold implications relevant to policy makers, management, and public health. ISO 14001 certification or EMS implementation should not be used as a proxy for continuous improvement of compliance, warned Matthews. There remains a need to bridge the information gap between the leadership and management system components of the organization and for EMS to address potential problems, especially non-regulated public health needs. In addition, a better communication between firms and stakeholders is needed, concluded Matthews. Some meeting participants suggested in the discussion that EMSs cannot be generalized, and that we need to move forward toward a more sustainable approach to governing. We need to recognize that organizations need a wide range of incentives and disincentives, and they need to be given every possible tool to assist them toward their goals. A combination of approaches coupled with command and control regulation, insurance and supply chain incentives, and community pressure can lead to sustainable improvement after a few years, noted general discussion participants. THE ENVIRONMENTAL IMPACT OF ENVIRONMENTAL MANAGEMENT SYSTEMS: FINDINGS FROM THE LITERATURE Environmental performance is defined as the reduction of pollution or resource uses, whether it is water or energy use, said Cary Coglianese of the Kennedy School of Government, Harvard University. The EMS is defined broadly as any kind of systematic management approach to identify environmental problems and to take action to respond to their plans.

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary According to Coglianese, a number of case studies suggest that EMSs can act as responsive tools to use fewer resources and generate less waste and pollution. For example, a Louisiana Pacific facility developed a corporate-wide environmental management system and, as a result, its facilities began to recognize new ways to recycle wood chips, causing a reduction in overall waste and company expenses (Coglianese and Nash, 2001). An Alcoa Corporation subsidiary in South Carolina cut waste generation in half after implementing an EMS, and in some of their facilities, they have been able to reduce the amount of waste that they generated by 50 percent (Rondinelli and Vastag, 2000). The environmental management system is defined broadly as any kind of systematic management approach to identify environmental problems and to take action to respond to those problems. —Cary Coglianese Another study focused on manufacturing facilities in Pennsylvania where 214 manufacturing facilities were asked whether they had implemented an EMS or a pollution prevention program within the company. Also, each facility was asked to report any progress in managing their environmental affairs. With this sample, statistically significant differences were found in achieved improvements in environmental management between the companies that had adopted an EMS and those that had not. For example, approximately 75 percent of the companies with an EMS had reported making reductions in air emissions, compared with about 40 percent of the facilities that had not implemented an EMS. Similar trends were reported for water pollution and for energy use (Florida and Davison, 2001). There were significant differences between what companies with an EMS were reporting, compared with companies without an EMS. A second large study at the University of Oregon studied 247 facilities in the electronic sector. A log of an index based upon toxic release inventory emissions was used to study the impact of the American Chemistry Council’s Responsible Care program. Two statistically significant results were found: (1) older facilities had higher toxic release inventory emissions; (2) facilities with EMSs had lower toxic release inventory emissions, compared with facilities that did not (Russo and Harrison, 2004). The large and the small studies present suggestive, but mixed, evidence that EMSs may make a difference. However, selection bias may affect results because each facility voluntarily chose to implement an EMS, perhaps making it unrepresentative of a typical firm. For example, facilities adopting an EMS voluntarily are likely to have managers committed to improving environmental performance, noted Coglianese. In this case, an EMS is a tool to be used to achieve that goal. The EMS may just be a representation or proxy for that underlying commitment. Firms with equal levels of commitment but that haven’t adopted an ISO 14001 system might nevertheless manage their operations in

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Global Environmental Health in the 21st Century: From Governmental Regulation to Corporate Social Responsibility - Workshop Summary ways that achieve their commitment to an improved environmental performance, suggested Coglianese. In seeking to understand why some companies performed better than others in their ability to reduce pollution, Coglianese examined management commitment to improving environmental performance. One study showed that leadership commitment played an important role in performance (Kagan, 2005). A survey of 617 facilities in the automobile sector—some of which have been required by General Motors and Ford to adopt an EMS—further tested the management commitment hypothesis. The survey found that firms with an EMS did not make substantial strides in reducing regulated air or water pollution (Andrews et al., 2005). However, they did make improvements in energy efficiency and managing spills. Further, a 2004 study analyzed facilities in states that had mandatory pollution prevention planning laws. The study found that facilities in states with pollution prevention programs reduced toxic release inventory releases by 62,000 pounds, or about an average of a 30 percent reduction (Bennear and Coglianese, 2004). However, studies also report diminishing environmental progress approximately 5–10 years after implementing planning processes. Overall, Coglianese is wary to suggest that an EMS is guaranteed to be an effective method for producing positive long-term environmental effects. In conclusion, Coglianese suggests that a required EMS can and does make environmental improvements, but one must use caution in distinguishing how much comes from the system and how much comes from the commitment. Systems don’t necessarily lead to improvements, but people and their commitment can. Nevertheless, even facilities that are required to adopt management systems or pollution prevention programs do demonstrate some performance improvements.