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An International Passport To Doing Business - The ISO 14001 Environmental
Management Systems
Ian Ireland
Law and Public Administration Group
Global consumer demand for environmentally friendly products, the 1992
Rio Earth Summit on the Environment and the proliferation of environmental
management regulations, has obliged corporations to pay increasing attention
to the environmental aspects of product design, production, packaging,
distribution and disposal.
Governments worldwide are interested in the role voluntary environmental
management systems can play as an alternative to complex mandatory environmental
regulations.
The developing International Standards Organisation (ISO) 14000 series
of environmental management standards describe the elements of an environmental
management system. The standards are voluntary, do not supplant the internal
regulatory regimes of a nation and are process rather than performance
standards.
The primary focus of this Current Issues Brief is the main
ISO environmental management standard being developed for use by corporations
and for independent third-party certification and registration purposes,
namely, ISO 14001. This paper also outlines the background to, and development
of, the ISO 14000 series of environmental management standards, reasons
for a corporation adopting ISO 14000, or governments integrating the standards
in their regulatory system, and points to a number of concerns about ISO
14000.
Why are the developing ISO 14000 series of standards important
to Australian corporations and governments? Although designed
as voluntary standards, compliance is likely to become a market driven
requirement for Australian corporations doing international business,
in much the same way as compliance with the ISO 9000 series of quality
management and assurance standards have. Overseas, a number of corporations
have already been certified under draft ISO 14001. In the Netherlands,
for example, the multinational corporation Akzo Nobel has announced plans
to introduce draft 14001 as a standard for environmental management systems
at all its sites.1
Australia's first certification to ISO 14001 was achieved in February
1996 by Alcoa's Kwinana refinery processing plant. Other organisations
in Australia seeking certification to ISO 14000 include Sydney Electricity,
Pacific Power, Southcorp Packaging and Simsmetal.
In relation to government involvement, Germany is examining the role
ISO 14000 can play in deregulatory efforts and in the simplification of
permitting procedures.2 Mexico, Canada and the United States have signed
a voluntary agreement to exchange information and technical expertise
for compliance with ISO 14000(3) and Colombia plans to give preference
in contracts to companies that comply with ISO 14000(4)
Development of the ISO 14000 Series
of Environmental Management Standards
The International Organisation for Standardisation
The International Organisation for Standardisation (ISO) is an international
organisation whose members are the national standards bodies of 111 countries.
The ISO was founded in 1946 to develop manufacturing, trade and communication
standards. Standards Australia is Australia's representative on the ISO.5
The ISO develops standards for all industries other than those relating
to electrical and electronic engineering. All standards developed by the
ISO are voluntary. The goals of the ISO are to facilitate the efficient
exchange of goods and services.6
The ISO comprises approximately 180 technical committees which are tasked
with drafting standards. ISO member nations form technical advisory groups
which provide input to the technical committees. Only after a draft standard
has been voted on by all ISO member countries is it published as an international
standard.
For the most part, the ISO has focused on the development of technical
standards. However, in 1979 the ISO formed Technical Committee 176 to
develop international standards for quality management and assurance systems.
The work of Technical Committee 176 resulted in the publication in 1987
of the ISO 9000 series of standards.
ISO 9000 standards provide the elements of a quality management system
and guidance on implementation. Basically, the standards focus on key
management matters, including the development of policies for quality
management and assurance, establishing and maintaining a system to achieve
quality objectives, measuring and monitoring progress and reviewing an
organisation's system. A corporation which receives ISO 9000 registration
is international recognised as having a documented quality management
and assurance system that is fully operational and consistently followed.
The Strategic Action Group on the Environment
In response to global consumer demand for environmentally friendly products,
the Rio Summit on the Environment and international acceptance of the
ISO 9000 quality management and assurance standards, the ISO formed in
1991 the Strategic Action Group on the Environment (SAGE) to make recommendations
relating to environmental standards. SAGE was tasked with investigating
whether an environmental standard could promote a common approach to environmental
management, enhance an organisation's ability to attain and measure improvements
in environmental performance, facilitate trade and remove trade barriers.
In 1992, SAGE recommended the establishment of an ISO Technical Committee,
(TC 207) for the development of international environmental management
standards.
The work of TC 207 on environmental management system standards, more
commonly referred to as the ISO 14000 series of environmental management
standards, focuses on the basic elements needed to establish and maintain
an effective environmental management system.7 Excluded from TC 207 work
are test methods for pollutants, setting limit values regarding pollutants
and effluents, setting environmental performance levels and standardisation
of products.8
TC 207 is divided into six subcommittees. The subcommittees are Environmental
Management System, Environmental Auditing, Environmental Labelling, Environmental
Performance Evaluation, Life Cycle Analysis and Environmental Aspects
in Product Standards.9
The major developing standards in the ISO 14000 series of environmental
management standards include:
- ISO 14001 - Environmental Management Systems - Specification With
Guidance For Use.
- ISO 14010 - Guidelines For Environmental Auditing. General Principles
Of Environmental Auditing.
- ISO 14012 - Guidelines For Environmental Auditing - Qualification
Criteria For Environmental Auditors.
- ISO 14015 - Environmental Site Assessments.
- ISO 14020 - Environmental Labelling - Basic Principles Of All Environmental
Labelling.
- ISO 14023 - Environmental Labelling - Testing and Verification Methodologies.
- ISO 14031 - Evaluation Of The Environmental Performance Of The Management
System And Its Relationship To The Environment.
- ISO 14040 - Environmental Management - Life Cycle Assessment - Principles
And Guidelines.
Australian Involvement in ISO 14000
Standards Australia is playing a central role in the development of
the ISO 14000 series of environmental management standards. Standards
Australia heads the Environmental Labelling Committee.
Standards Australia and the Standards Council of Canada proposed in
May 1995 the development by TC 207 of a guidance standard entitled Guide
to Application of ISO 14001 in the Forestry Sector for Sustainable Forest
Management. This standard would have described how to implement ISO
14001 and the principles of sustainable forest management. The proposal
was opposed by environmental groups and industry groups. The proposal
was withdrawn at the June 1995 TC 207 meeting and instead presented as
a discussion document for the purpose of furthering debate amongst parties
interested in advancing sustainable forestry principles.
ISO 14001 - Environmental Management
Systems
OUTLINE
ISO 14001 specifies the core elements of an environmental management
system. The core elements are environmental policy, planning, implementation
and operation, checking and corrective action and management review.
'Environment' is defined in ISO 14001 as surroundings in which an organisation
operates, including air, water, land natural resources, flora, fauna,
humans, and their interrelation. The environment in this context extends
from within the organisation to the global system.10
'Environmental impact' is defined in ISO 14001 as any change to the
environment, whether adverse or beneficial, wholly or partially resulting
from an organisation's activities, products or services.11
'Environmental management system' is defined in ISO 14001 as the organisational
structure, responsibilities, practices, procedures, processes and resources
for implementing and maintaining environmental management.12
'Environmental management system audit' is defined in ISO 14001 as the
systematic and documented verification process to objectively obtain and
evaluate evidence to determine whether an organisation's environmental
management system conforms to the environmental management system audit
criteria set by the organisation, and communication of the results of
this process to management.13
'Environmental performance' is defined in ISO 14001 as the measurable
outputs of the environmental management system, relating to an organisation's
control of the impacts of its activities, products or services on the
environment, based on its environmental policy, objectives and targets.14
'Organisation' is defined in ISO 14001 as a company, operation, firm,
enterprise, institution or association, or part thereof, whether incorporated
or not, public or private.15
ISO 14001 is applicable to any organisation that wishes to:
- implement, maintain and improve an environmental management system
- assure itself of its conformance with its stated environmental policy
- demonstrate such conformance to others
- seek certification/registration of its environmental management system
by an external organisation
- make a self determination and declaration of conformance with the
standard.16
Core Elements of an Environmental Management
System
(1) Environmental Policy
To comply with ISO 14001 an organisation must establish and maintain
an environmental management system.17 Top management must define the organisation's
environmental policy and ensure that it:
- is appropriate to the nature, scale and environmental impacts of its
activities, products or services
- includes a commitment to continual improvement and prevention of pollution
- includes a commitment to comply with relevant environmental legislation
and regulations, and with other requirements to which the organisation
subscribes
- provides the framework for setting and reviewing environmental objectives
and targets
- is documented, implemented and maintained and communicated to all
employees
- is available to the public.18
(2) Planning
The planning component of an organisation's environmental management
system must comprise the establishment and maintenance of:
- a procedure to identify the environmental aspects of its activities,
products or services in order to determine those which have or can have
significant impacts on the environment19
- a procedure to identify and have access to legal and other requirements
to which the organisation determines to be directly applicable to the
environmental aspects of its activities, products or services20
- documented environmental objectives and targets at each relevant function
and level within the organisation21
- program/s for achieving its environmental objectives and targets.22
(3) Implementation and Operation
The third core element of the environmental management system process
is the implementation of an organisation's environmental management policy
and the operational control of the organisation's activities and operations
in line with its policy, objectives and targets.
The third element focuses on:
- structure and responsibility
- training, awareness and competence
- communications
- environmental management system documentation
- document control
- operational control
- emergency preparedness and response.
The key requirements imposed by the third element include:
Structure and Responsibility - The roles, responsibilities
and authorities of an organisation must be defined, documented and communicated.23
The management of an organisation must also provide the resources necessary
for the implementation and control of the environmental management system.24
Training, Awareness and Competence - An organisation
must identify its training needs; require that all personnel whose work
may create a significant environmental impact receive appropriate training.
Operational Control - An organisation must identify
its operations and activities associated with the identified significant
environmental impacts and which come within its policy, objectives and
targets.25
Emergency Preparedness and Response - An organisation
must establish and maintain procedures to identify potential for and respond
to accidents and emergency situations, and for preventing and lessening
the environmental impacts that may be associated with such accidents and
emergencies.26
(4) Checking and Corrective Action
A fourth core element of the environmental management system process
focuses on:
- monitoring and measurement of the key characteristics of an organisation's
operations and activities that can have a significant impact on the
environment
- the establishment and maintenance of procedures for defining responsibility
and authority for handling and investigating non-conformance, taking
action to lessen any impacts caused and for initiating corrective and
preventive action
- the establishment and maintenance of procedures for the identification,
maintenance and disposition of environmental records
- the establishment and maintenance of a programme/s and procedures
for periodic environmental management system audits.
The key requirements imposed by the fourth element include:
Monitoring and Measurement - An organisation must
establish and maintain procedures to monitor and measure regularly the
key characteristics of its operations and activities that may have a significant
impact on the environment.27
Non-Conformance and Corrective and Preventive Action -
An organisation must establish and maintain procedures for defining responsibility
and authority, for handling and investigating non-conformance, taking
action to lessen any impacts caused and for taking corrective and preventive
action.28
Environmental Management System Audit - An organisation
must establish and maintain a program/s and procedures for periodic environmental
management system audits.29
(5) Management Review
The final core element of the environmental management system process
requires the top management of an organisation to review its environmental
management system.30 The objective of a review is to enable an organisation
to ensure the continuing suitability, adequacy and effectiveness of its
environmental management system.31
What Do The ISO 14000 Series Of Environmental
Management Standards Offer An Australian Organisation?
There are a number of reasons for corporations implementing the ISO
14000 series of environmental management standards, or governments integrating
the standards in their regulatory systems. The ISO 14000 standards allow
organisations to focus their environmental efforts on a single internationally
accepted set of criteria.
International standards, such as the ISO 14000 series of environmental
standards, facilitate a common industrial language, provides consumer
confidence, promotes safety and encourage trade by making it more efficient
and by simplifying testing and certification requirements.32
Implementing an environmental management system that complies with ISO
14001 and obtaining registration could become a defacto requirement for
doing international business, much as the ISO 9000 series of quality management
and assurance standards have. Companies have implemented ISO 9000 to maintain
market share, keep up with, or get ahead of their competitors.33
Organisations are increasingly concerned with satisfying the expectations
of a broad range of parties, including investors, the public and environmental
groups. Organisations with ISO 14000 registration can provide confidence
to the public that they are complying with regulatory requirements and
continually improving their environmental management systems.34
Implementation of an internationally recognised environmental management
system can provide an organisation with future savings in the form of
insurance rates and better access to capital. Insurance companies may
be more willing to provide cover, or at a lower premium, for pollution
incidents if the organisation seeking the cover has a proven and internationally
recognised environmental management system in place.35
ISO 14000 can provide a mechanism for an organisation to create an environmental
management system where non exists. In addition, ISO 14000 can help an
organisation systematically monitor and measure its compliance status,
train employees regarding their role in environmental protection and improvement,
and integrate existing management systems to reduce costs and duplication.36
Concerns With The ISO 14000 Series Of
Environmental Management Standards
The benefits outlined above for corporations implementing the ISO 14000
series of environmental management standards, or governments integrating
the standards in their regulatory systems should not hide the concerns
and pitfalls inherent in the implementation of ISO 14000. Implementation
may be costly. For small and medium sized organisations the time and cost
of obtaining ISO 14000 registration may be prohibitive.
ISO 14000 registration does not guarantee that an organisation has achieved
the best environmental performance, only that it has the basic elements
of an environmental management system in place.37
The ISO 14000 series of environmental management standards are process
rather than performance standards. In other words, ISO 14000 does not
tell organisations what environmental performance they must achieve. The
standards only offer a system for helping organisations achieve their
own goals. Those goals may only be token.
The requirements for ISO 14001 registration can disadvantage developing
nations. If registration is expensive and the standards too prescriptive
to meet, developing nations will be disadvantaged.38 ISO 14001 could be
said to be imposing the environmental requirements and management systems
of advanced industrial nations on developing nations, requirements they
lack the resources to meet.
The registration and accreditation requirements necessitated by ISO
14000 may operate to require organisations in nations without a developed
registration and accreditation infrastructure to seek registration and
accreditation in other nations, thus driving up the costs. 39
The ISO 14000 series of environmental management standards do not set
limit values regarding pollutants and effluent and environmental performance
levels.
ISO 14000 is a dynamic and rapidly evolving change agent, the first
international attempt to standardise a systematic approach to environmental
management. Even though formal publication of the first ISO 14000 standard
has yet to occur, the ISO 14000 movement is here to stay and may become
a requirement for Australian corporations doing international business.
While the development to date of ISO 14000 can be said to have been
market driven, its continued development will depend to a large extent
on how governments world wide interpret the impact it has, or can play,
in nations' environmental regulatory systems.
Because ISO 14000 has the potential to be a change agent of national
and global significance, a change agent which may touch every aspect of
the way a nation's industries confront environmental protection management,
governments worldwide will have to examin the potential impact of ISO
14000 will have on their domestic regulatory systems, environmental enforcement
procedures and the position their nation adopts at the international level.
- International Environment Reporter, February 7 1996.
- Tom Tibor & Ira Feldman, ISO 14000 A Guide to the New Environmental
Management Standards, Irwin Professional Publishing, 1996, p. 10.
- nternational Environment Reporter, 7 February 1996.
- Tom Tibor & Ira Feldman, ISO 14000 A Guide to the New Environmental
Management Standards, Irwin Professional Publishing, 1996, p. 18.
- Standards Australia is the trading name of the Standards Association
of Australia, an independent non-profit organisation whose principal
objective is to facilitate the preparation, publication and adoption
of Australian standards. Standards Australia is accountable to its members
(12 000) and the general public for maintaining the transparency and
integrity of Australia's voluntary consensus system of standardisation.
Standards Australia derives 65% of its revenue from sales of publications
and related services, 8% from membership contributions, 12% from a Commonwealth
Government grant and 15% from miscellaneous sources. Source: Standards
Australia, Annual Report 1994, pp. 2-3 and 16.
- Tom Tibor & Ira Feldman,ISO 14000 A Guide to the New Environmental
Management Standards, Irwin Professional Publishing, 1996, p.
27.
- Ibid., at p. 35.
- Ibid., at p. 34.
- Ibid., at p. 36.
- Ibid., sub-clause 3.2.
- Ibid., sub-clause 3.4.
- Ibid., sub-clause 3.6.
- Ibid., sub-clause 3.7.
- Ibid., sub-clause 3.9.
- Ibid., sub-clause 3.13.
- Ibid., clause 1.
- Ibid., clause 4.0.
- Ibid., sub-clause 4.1.
- Ibid., sub-clause 4.2.1.
- Ibid., sub-clause 4.2.2.
- Ibid., sub-clause 4.2.3.
- Ibid., sub-clause 4.2.4.
- Ibid., sub-clause 4.3.1.
- Ibid.
- Ibid., sub-clause 4.3.6.
- Ibid., sub-clause 4.3.7.
- Ibid., sub-clause 4.4.1.
- Ibid., sub-clause 4.4.2.
- Ibid., sub-clause 4.4.4.
- Ibid., clause 4.5.
- Ibid.
- Ibid., at p. 15.
- Ibid., at pp. 9 and 31.
- Ibid., at p. 12.
- Ibid., at p. 13.
- Ibid.
- Ibid., at p. 49.
- Ibid., at p. 16.
- Ibid.
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