The future of environmental management with ISO 14000

IN INDUSTRIAL SETTINGS, environmental management (EM) involves administering the control of wastes in compliance with relevant regulations. Control is usually implemented during the course of routine operations but the process employed and the flowsheets used are designated during the planning processes of the project design phase. At this juncture the project team must apply a systems approach to environmental concerns. The ISO 14000 series will aid this effort—and not only during the design phase. These international standards propose to permeate the entire context of management, imposing a procedurebased approach to all matters of environmental protection.

Background on ISO 14000. The International Organization of Standards (ISO) is a body representing the standards institutes of 120 countries. The American National Standards Institute (ANSI) is the official U.S. body. The Registrar Accreditation Board (RAB) officially administers accreditation programs in the U.S. ANSI and RAB have joined to operate the National Accreditation Program (NAP). NAP will be responsible for accreditation of organizations to register to ISO 14000 standards, and accreditation of ISO 14000 auditor training course providers. The NAP Council officially opened for business on December 10, 1996, and is working with selected firms that can provide the auditing and training functions.

ISO 14000 is a shorthand phrase used to refer to a series of about 20 EM standards, collectively employing a systems-based approach (see sidebar). They are being or have been developed by Technical Committee 207 (TC 207) under ISO. TC 207 has delegates from 69 countries, including the U.S. and Canada. Standard 14001 on Specification With Guidance For Use, and 14004 on General Guidelines On Principles, Systems and Supporting Techniques were published in September 1996 after a two-year preparation period. Standard 14001 is of the most interest and concern, as it is the specification standard used for registration.

This series presents process standards for voluntary compliance; they do not set performance levels, rates of improvements, or prescriptive goals, objectives or policies. The underlying assumption is that better environmental management, with a desire for continual improvement, will lead to better environmental performance. ISO 14000 implementation is a phrase that can mean two courses of action: (1) an organization agrees to register, thereby adhering to a process where an independent third party audits the EM system to evaluate whether it conforms to the guidelines of ISO 14001, or (2) an organization volunteers to use ISO 14001 internally without seeking third-party registration.

Other standards, regulations or initiatives that have served as precedents in developing ISO 14000 include ISO 9000 (the quality management standard),Total Quality Management (TQM) and Total Quality Environmental Management (TQEM), the British EMS 7750, the European Eco-Management Audit System (EMAS), the EPA's Pollution Prevention Assessment Program and 33/50 Program, the Chemical Manufacturer's Responsible Care Program, the Global Environmental Management Initiative's self-assessment standards, the International Chamber of Commerce's Business Charter for Sustainable Development. Each of these has an intent and purpose separate from ISO 14000. Both EMS 7750 and EMAS served as models for ISO 14000 but they differ by being performance-based standards, so they will not be superseded by the ISO 14000 but, instead, augmented.

Background on Environmental Protection in the U.S. In the early 1970s, a succession of laws were enacted and regulations promulgated to control the release of hazardous and toxic chemicals and substances into the environment. The U.S. Environmental Protection Agency (EPA) is the official implementing agency for the regulations. Some laws and regulations of significance to industrial practices include the Clean Air Act (CAA) of 1970 (amended 1990), the Safe Drinking Water Act of 1974 (amended 1996), the Toxic Substance Control Act of 1976, the Clean Water Act (CWA) of 1977, the Resource Conservation and Recovery Act (RCRA) of 1976 (amended 1984), the Comprehensive Environmental Response, Compensation and Liability Act (CER-CLA) of 1980 (amended 1986), and the Pollution Prevention Act (PPA) of 1990. Details on these regulations and other EPA activities can be found through links on their home page at www.epa.gov.

The implementation of these regulations, and particularly the PPA, has resulted in a significant reduction in the release of pollutants to the environment by changing the way industry addresses control. Instead of controlling pollution at the end of the pipe for water-borne contaminants or the stack for air-borne contaminants, pollution prevention offers a four-step hierarchical approach: source reduction, recycling, treatment, and safe disposal of residues. Specific industries such as pulp and paper have developed benchmark processes applying source reduction with outstanding results.

So, what do the environmental protection regulations cover? The easy answer is any hazardous or toxic substance that poses a health risk to humans and other animals, or destroys plant life. A little longer answer will give you a better feel from a regulatory viewpoint. The National Emission Standard for Hazardous Air Pollutants (NESHAP) from Title I of the CAA lists 200 substances with emphasis on six chemicals and the generic category of radionuclides. CWA Priority Pollutants include 126 chemicals. RCRA in defining hazardous waste lists over 400 discarded chemical products and specific chemical constituents of industrial waste streams. The CERCLA amendment is called the Superfund Amendments and Reauthorization Act (SARA). Title III of SARA lists more than 320 toxic substances; Section 302 lists 360 extremely hazardous substances for which facilities are required to prepare emergency action plans if quantities exceed certain limits. It is an understatement to say that federal and state environmental regulations are voluminous: their 60,000 pages are continually being updated and/or revised.

Benefits and Drawbacks. What impetus does industry have to implement the ISO 14000 standard series? For one thing, the proliferation of other EM standards and voluntary initiatives throughout the many countries of the world complicates international marketing. A common international standard is needed to enhance trade between countries and override barriers that multiple standards impose. In addition, there appears to be a growing international concern, inspired by consumers, for all countries and organizations to embrace environmental stewardship and accountability. This forces companies to approach EM from a strategic rather than compliance perspective. And that can create additional competitive advantages, because of internal benefits such as more efficient operation, less energy usage, recycling, lower insurance rates, and fewer permits. Also, ISO 14000 examines the life cycle of a product— a cradle-to-new-cradle approach with a minimal amount on cradle-to-grave—providing further sources of savings or cost reduction.

Furthermore, the ISO series allows governments with strict regulations to move from the command and control approach to a less demanding and less costly preventive approach with more focus on poor performers. And, there is more incentive to initiate pollution prevention activities, which are showing great success.

Can there be a downside to ISO 14000 implementation? Maybe. According to the Environmental and Society Group at the Battelle Seattle Research Center operating costs will increase at first, and these losses may not be recovered depending on a number of business factors and policy decisions. Some small and medium-sized enterprises may find the costs and time prohibitive, while enterprises in developing nations may not be able to compete globally.

In addition, if the expectations of ISO 14000 are not met, they can actually lead to poorer performance. And the precautionary principle, which argues that industry should take action to reduce potential environmental impact even in the absence of conclusive proof of the impact, is not defined.

Stakeholder Reactions. In the regulatory community, there is concern about the effectiveness of implementing ISO 14000 due to the procedural rather than performance-based approach. They are resolute about retaining the existing enforceable codes but generally optimistic about the deliberative process of imposing ISO 14000 on top of existing standards, regulations, guidelines and initiatives. EPA participates in developmental or draft stages of ISO 14000 standards. State agencies have expressed concern about the objectivity of audits, definition of compliance, the role of third-party audits, and stakeholder roles.

In industry, large corporations see benefits and favor U.S. adoption, particularly for foreign markets. Small and medium enterprises are cautious.

The legal community representing industry recognizes that ISO 14000 can provide long-term benefit but not without corporations establishing strong EM systems with significant legal input. Attorneys believe that corporations must understand what ISO 14000 will and will not do, and the risks associated with a third-party auditor.

Policy-makers feel that the standards provide opportunities for moving environmental compliance monitoring to a less adversarial context.

In an international community, Great Britain is implementing the EMS 7750 and the rest of Europe has adopted EMAS, both of which are predecessors to ISO 14000. The Pacific Rim nations, and especially Japan, are eager to implement ISO 14000 with its enhanced economic potential. Smaller and less developed nations are seeking inclusion of some incentives for their benefit as they comment on the developmental stages of the standards.

Activists and watchdogs are cautious but optimistic that ISO 14000 will enhance environmental stewardship. They are concerned that ISO 14000 implementation could lead to less enforcement by regulating agencies and that regulators would become too cozy with business.

ALTHOUGH MUCH HAS been accomplished since the onset of the environmental age in the early 1970s and the global acceptance of the concepts of pollution prevention have and will continue to offer remarkable improvements, ISO 14000 provides a new, consolidated approach, taking the best elements of its precursors. Global marketing will encourage global adoption of ISO 14000, and Europe and Asia are leading the way. Large U.S. companies with global interests are implementing ISO 14000 and encouraging federal and state governments to incorporate ISO 14000 into their policy and programs. With global implementation of ISO 14000 by industrial enterprises, an environmental ethic may pervade corporate strategic goals and operational policy in years to come and relieve regulators from the costly command and control approach to enforcement. ■

Don Merrick, PE, is an independent engineering consultant and member of the Puget Sound PMI Chapter. He has 25 years of experience in environmental engineering and management and can be reached by e-mail at [email protected].