Chapter 5
International Organization for Standardization: Environmental Management Systems Standards

Lynne Anderson

ISO 14000 West Coast Working Group

For many reasons, corporations have begun to look closely at integrated environmental management. This scrutiny has been aimed at reducing risk, becoming better corporate citizens, improving their public image, responding to shareholder concerns, and improving the workplace environment. An underlying reason for these goals is to improve a company's environmental performance. In response to this growing interest in environmental performance, the International Organization for Standardization (ISO) confirmed the need for and agreed to prepare an international consensus document for Environmental Management Systems (EMS). In 1992, ISO formed a Technical Committee on Environmental Management (TC 207) with a scope that included the "standardization in the field of environmental management tools and systems" (International Organization for Standardization, 1996. Environmental Management Systems). ISO specifically excluded from this scope test methods and limit values for air, water, soil, and noise pollution; specified environmental performance levels; and the standardization of products.

Since its formation, TC 207 has been working in several areas to produce international consensus agreements to publish as voluntary standards. These include EMSs, environmental auditing, environmental labeling, environmental performance evaluation, and life-cycle assessment. The first document to reach the International Standard stage was ISO 14001, published as "Environmental Management Systems—Specification with Guidance for Use," September 1, 1996, First Edition (International Organization for Standardization, 1996). This chapter reviews the genesis and components of ISO 14001 and discusses the existing options for determining conformity with ISO 14001.



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Chapter 5 International Organization for Standardization: Environmental Management Systems Standards Lynne Anderson ISO 14000 West Coast Working Group For many reasons, corporations have begun to look closely at integrated environmental management. This scrutiny has been aimed at reducing risk, becoming better corporate citizens, improving their public image, responding to shareholder concerns, and improving the workplace environment. An underlying reason for these goals is to improve a company's environmental performance. In response to this growing interest in environmental performance, the International Organization for Standardization (ISO) confirmed the need for and agreed to prepare an international consensus document for Environmental Management Systems (EMS). In 1992, ISO formed a Technical Committee on Environmental Management (TC 207) with a scope that included the "standardization in the field of environmental management tools and systems" (International Organization for Standardization, 1996. Environmental Management Systems). ISO specifically excluded from this scope test methods and limit values for air, water, soil, and noise pollution; specified environmental performance levels; and the standardization of products. Since its formation, TC 207 has been working in several areas to produce international consensus agreements to publish as voluntary standards. These include EMSs, environmental auditing, environmental labeling, environmental performance evaluation, and life-cycle assessment. The first document to reach the International Standard stage was ISO 14001, published as "Environmental Management Systems—Specification with Guidance for Use," September 1, 1996, First Edition (International Organization for Standardization, 1996). This chapter reviews the genesis and components of ISO 14001 and discusses the existing options for determining conformity with ISO 14001.

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Genesis Often referred to as a "paradigm shift," ISO 14001 represents the culmination of thinking regarding the way to manage environmental performance. Although ISO 14001 is a new standard, the concept of environmental management systems has been around for many years. In fact, ISO used preexisting standards, regulations, and charters, including ISO 9000 Quality Management Systems, the British Standard BS 7750 (International Organization for Standardization, 1996), the European Union Eco-Management and Audit Scheme (EMAS) (International Organization for Standardization, 1996), and the International Chamber of Commerce Business Charter for Sustainable Development as a starting point for drafting ISO 14001. Although the principles included in ISO 14001 are not new, it represents a multistakeholder, international consensus opinion on EMS. This consensus approach is intended to engender broad-based international acceptance and use of ISO 14000. General Components Divided into five sections, ISO 14001 outlines the process an enterprise considers to manage environmental matters. The key principles include items such as a well defined process for planning, support and commitment of top management, the identification of individuals and procedures to implement plans, the communication of those plans, and a process of review. In this way, ISO embraced a "plan-do-review," approach to environmental management. Policy ISO considered the environmental policy as the source from which an organization should derive the particulars of its system. It contemplated this environmental policy as the "driver for implementing and improving the organization's EMS" (ISO 14001, Annex A, Section A.2). To act as such a driver, ISO recognized the vital importance of upper-level management involvement in and commitment to an environmental policy. Thus, ISO 14001, Section 4.2, requires top management to define its environmental policy. Although mandatory, ISO recognized that policies will necessarily vary from organization to organization. However, minimum requirements for such a policy are mandated by the EMS. They include commitment to continual improvement of the environmental management system, the prevention of pollution, and the compliance with applicable environmental laws and regulations.

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Planning As the next step toward an EMS, ISO recognized that all organizations must take stock of environmental matters, set goals for their improvement, and make provisions to achieve the goals. To be applicable to a range of enterprises, ISO did not specify goals. Instead, the planning section of the EMS requires minimum components of a planning process and leaves to the enterprise the specification of details for the EMS. ISO 14001 Section 4.3 has been distilled by many to read, "Say what you do...." In this planning stage, ISO set forth the following steps: identify environmental aspects and legal and other requirements, set objectives and targets, and establish a formal environmental management program. For the environmental aspects and legal requirements, ISO 14001 requires an organization to "establish and maintain procedures" to identify its environmental aspects and legal and other requirements. An organization also must establish, maintain, and document its objectives and targets for all relevant levels of the organization. Under an informative guidance on the use of the specification, ISO further states that these objectives and targets must be "measurable wherever practicable" (ISO 14001, Annex A, Section A.3.3). These objectives and targets also are linked directly to the implementation and operation section of ISO 14001. Implementation and Operation Colloquially, the language in ISO 14001, Section 4.4 requires an organization to "...do what you say." Certain of those requirements relate to the human aspects of an EMS and include roles and responsibility, education, communication, and training. The remaining requirements focus more on procedural matters of an enterprise. They include document control, operational control, and emergency preparedness and response. To implement ISO 14001, an organization will necessarily rely on individuals. ISO requires the organization to determine who will implement the various components of its EMS, how it will communicate information to all levels of the organization, and how it will provide the necessary resources and training to do so. Here again, ISO refrains from mandating specific action, recognizing that the "how" will necessarily vary from one organization to another. The procedural components of ISO 14001.4.4.5 require an organization to have a documentation system that contains the core elements of the EMS and that is readily obtainable. An organization also must examine its operations and activities (normal, abnormal, and emergency) and link that information with the identification of "significant" environmental aspects and the setting of relevant objectives and targets for improvement. Specifically, ISO 14001 requires an organization to understand how its operations affect the environment and to re-

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late those effects to continual improvement of its EMS and the prevention of pollution. In ISO 14001.4.4.6, the threshold for "significance" is left to the organization. The operational control section of the standard also contains the only reference to suppliers and contractors. Although not clearly articulated, ISO 14001 requires an organization to understand how suppliers and contractors produce "significant environmental aspects" and to determine whether there are any relevant operational procedures and activities that should be communicated to suppliers and contractors. Unlike other existing EMS standards, ISO 14001 stops short of requiring an organization to police its suppliers and contractors. Finally, the implementation portion of ISO 14001 requires an organization to make plans for response to accidents and emergency situations and for preventing and mitigating the environmental impacts associated with them. ISO also suggests that the organization test such procedures where "practicable." The meaning of "practicable" is left for the individual organization to determine. Checking and Correction Action ISO 14001 requires an organization to establish and maintain documented procedures to monitor and measure "key characteristics" of its operation that can have "significant impact" on the environment. The organization also must develop procedures for handling events of nonconformance with the EMS, mitigating environmental impacts, and performing corrective and preventive action. ISO 14001 also suggests that the organization review its documented procedures after any corrective or preventive action is taken. An organization's records established pursuant to an EMS must be managed. The standard specifies that records that concern training, audit results, and management reviews must be developed and maintained. The records must be of sufficient quality to enable them to be understood, relevant, available, and safe from damage, deterioration, or loss. The organization also must establish and maintain an audit program to determine conformance with the EMS and provide information on results to management. Required components of the audit program include its scope, its frequency, the audit methods used, a roster of the audit team, and the audit report. Management Review "Top management," not otherwise defined by ISO 14001, must collect information on the suitability of its EMS and perform a review. These reviews must be conducted "periodically." The period of such a review is determined by the organization. The purpose of the review is to ensure the adequacy and effectiveness of its EMS.

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Conformance with ISO 14001 Conformity assessment guidance and options are under development by ISO and multiple national and regional accreditation bodies in parallel with the development of the EMS standards. ISO 14001 provides two options for conforming with the standard. ISO 14001 recognizes that demonstrating to others a conformance to the standard may proceed through third-party certification or through a self-determination and declaration of conformance with the standard (ISO 14001 Section 1). ISO 14001 contains the self-determination option to allow individual organizations to choose whether and when to share information outside of the organization. However, the common belief is that most organizations will seek third-party registration in an effort to bypass any questions regarding the potential bias of a self-conformance claim. ISO 14001 is silent on the subject of procedures for determining conformance with ISO 14001. The development of guidelines for conformity assessment is instead under the control of a separate ISO committee. The ISO Conformity Assessment Committee (CASCO) provides guidelines for conformity assessment, which help national accreditation bodies and registrars develop programs for assessing conformity to ISO standards. One of the significant issues to be worked out regarding accreditation is the transboundary use of accreditors. With the late arrival of a U.S.-based accreditation scheme, registration in the United States has occurred through other nationally accredited registration. Will there be a meaningful difference between a U.S. or a E.U. based accreditation scheme? The practical application of the various accreditation schemes bears watching in the future. Conclusion Since the mid 1980s, industry and government initiatives in environmental management proliferated, which in turn encouraged ISO to produce a multistakeholder, international opinion on EMS. Using a consensus approach, ISO has endeavored to prepare a standard on EMS that will be flexible enough to accommodate a variety of organizations operating in a multitude of cultures. The overarching goal for ISO was to provide a document that would encourage the adoption of an EMS, which in turn would promote improved environmental performance. Because ISO 14001 is recently adopted, the use of such a standard bears scrutiny of any company considering its environmental performance. References International Organization for Standardization (ISO 14001). 1996. Environmental Management Systems. International Organization for Standardization (ISO 14001). 1996. Environmental Management Systems. Annex A. Guidance and the Use of the Specification.