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GeoInsighter Summer 2002 Newsletter ISO
14001 Return to the Newsletter Index In the last article on environmental management systems or "EMS" (GeoInsighter, Winter/Spring 2002), some basic considerations with regard to the whys and wherefores of EMS were discussed, including a delineation of fundamental elements. In this issue, we focus on the International Standards Organization ("ISO") International Standard for Environmental Management Systems, ISO 14001.
Of the management systems in use, the ISO 14001 standard is perhaps the most popular and has, to some extent, become the baseline against which all EMS, formal and informal, are measured. There are several reasons for this. First, market penetration by the now familiar ISO 9000 quality management standard has paved the way for ISO 14001. Structurally and functionally similar to ISO 9000, ISO 14001 is recognizable, and, for organizations that have pursued ISO 9000, the path to ISO 14001 seems familiar and, consequently, less intimidating. The similarities among the two are so great that ISO is working towards integration of the standards; a factor that all ISO 9000 certified organizations should keep in mind. Second, ISO 14001 is a certification standard, in that conformance to the standard is certified by third-party auditors. This can be an advantage to an organization in its marketing and in its relationships with the community, outside parties, and regulatory authorities, due to the credibility associated with independent certification. While the marketing value of ISO certification is a subject of much debate and is likely to be strongly dependent upon the details of a specific organization's situation, the relationship value is much clearer. This can be seen in the United States Environmental Protection Agency policy indicating that the presence of an EMS will be considered a mitigating factor in penalty assessment in enforcement actions. Finally, the standard is designed to provide flexibility in implementation so that it remains applicable and usable to a broad spectrum of organizations. This is in contrast to a variety of other industry- or sector-specific management systems. While it is the case that the standard provides a general template and process for implementation of a management system and ostensible systems that depart from the letter, but not the intent, of the standard can be certified, practical experience has identified limits to applicability and flexibility of the standard. This is particularly true with respect to small organizations, where the administrative demands of the standard may strain available resources or simply be infeasible as a matter of practice. ISO recognizes this and is developing guidance for small organizations. Further, because ISO 14001 is a certification standard, the need for consistency in auditing has limited some of the intended flexibility of the standard. Experience has been that unique management systems are more difficult to certify than those that closely follow the language and structure of the standard, simply because it is more difficult for auditors to recognize the elements of the system. Unfortunately, design for ease of audit often wins out over design for organizational utility. If your organization is considering implementing an EMS using the ISO 14001 standard, there is an important issue to bear in mind. ISO 14001 is not a compliance standard. The ISO and third-party auditors will not certify that your operations are in regulatory compliance. Your system is certified, not the outcome of the use of the system. While achieving certification will be easier from a starting point of substantial compliance, it is by no means necessary; nor will achieving certification assure regulatory compliance. The ISO 14001 standard requires a commitment to compliance, and the presumption is that systematic management of your environmental impacts will further compliance. But the scope is broader. ISO 14001 contemplates management of all environmental interactions (called aspects in the standard), regardless of regulatory standing. If this is the direction your organization is heading, ISO 14001 may well be worth careful consideration. Please look for additional discussion of EMS in future issues.
Christopher M. Rawnsley
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