Thursday, 25 July 2013

THE FUTURE OF EMS (II)





Another significant change in the proposed revision to 14001 is the broadening of the scope of the EMS to consider environmental impacts throughout organisations’ value chains. The draft standard states that users should identify environmental aspects that it can control and “those it can influence considering a life-cycle perspective”.

Such an approach provides organisations with the opportunity to think about environment management not only as risk control, but also to consider the value it can add to their businesses, according to Bidwell. “Increasingly, there seems to be a dual stream approach to environment and sustainability management, with traditional environment managers thinking about pollution prevention, while other companies are changing their business plan to align themselves with issues like sustainable resource use.

“By talking more about the life cycle of a product or service, 14001 is now catching up with best practice in terms of sustainability. Sometimes the environmental implications of products are not immediately apparent to companies. For example, a sheetmetal manufacturer might not realise the influence it can have on a client’s technical plans to use less material. If environmental issues are embedded in the product design process and considered across the life cycle, this can be of real value to clients,” Bidwell argues.

The draft standard also includes a new clause on managing environmental aspects throughout value chains. It states that certified organisations must ensure that all processes related to significant aspects, both “upstream and downstream” the value chain, are “controlled or influenced”.

“Making it explicit that systems should consider impacts outside of direct operations is an important one,” says Symons. “But it would be stronger if there was more balance in the text between buying decisions and products in use. At the moment, while there is plenty of text on buying decisions, product impacts get only a handful of words – in spite of this being most firms’ largest impact.”

Meanwhile, Holman believes that the draft text on value chains could be improved. “There’s a small piece of text on the value chain, which is followed by four explanatory notes. I think it needs to be more concise and clearer about what’s expected from organisations,” she says.

“My company has more than 1,200 suppliers and subcontractors and has projects all over the world. While we already assess all our suppliers before we work with them, if we have to apply a full life-cycle approach it would be difficult.”

In contrast to Holman, who suggests more guidance is needed, Ledwith argues that it is best that the final standard avoids being too prescriptive. “Standards have to be quite top level, so each individual organisation can decide how it applies to them,” she says. “If ISO writes it down in black and white, something might be relevant to one company and not another.”

Ledwith comments that it will take some time for organisations to really get to grips with this part of the new standard. “There’s going to be an element of people asking what they should be doing. Only once the standard has been adopted and audited against will we find those case studies on what’s good and how far down the supply chain people should be going.”




Environmental Performance

One of the criticisms frequently levelled at the current version of 14001 is that the standard does not necessarily drive improvements in the environmental performance of its users, with assessment focused on evaluating whether an effective EMS is in place. Robins at Wiles Greenworld believes that the standard’s writers have gone some way to help tackle this issue in the proposed draft.

The “continual improvement” clause in the revised standard states: “[Users] shall continually improve the suitability, adequacy and effectiveness of the EMS, to enhance its environmental performance as set by top management in line with the environmental policy.”

“On first reading this I was concerned that environmental performance was being defined as measuring impact and not when mitigating it,” says Robins. “That was until I went back and reread the clause on environmental policy, which emphasises more strongly commitments to pollution prevention and environmental protection.

“A huge amount of thought has gone into this standard and how it all links together. There is a stronger emphasis on the requirement for continuous improvement, in line with the policy set by top management, so hopefully there’s less room for misinterpretation,” says Robins.

He does, however, acknowledge that much of potential benefit in this shift of emphasis is reliant on how auditors assess against the standard.

Other changes, including the move to make an EMS more strategic and the consideration of environmental conditions, are equally dependent on how the standard is audited, according to Vivian, and may pose a considerable challenge for assessors.

“The ability for an auditor to interpret how users are strategically managing adaptation to environmental conditions is both important and technical,” he says. “I’ve asked a lot of people about how they would do it and none have much of a clue; it’s a tough thing to do.”

Vivian believes a further benefit of the proposed new standard is that it talks about the EMS as a whole. “It leads the organisation to decide where in the EMS the management of significant aspects best sits for them, rather than directing people to do it under certain aspects, such as training or operational control.”

However, this creates a complication for those certifying the EMS, he says, particularly if they have expectations of where certain issues should be managed in a system. “Some certification auditors will have to be more imaginative about how they assess organisations, considering the effectiveness of the approach of the EMS for the company. This means that the audit process is likely to be less formulaic and will have a greater degree of subjectivity.


Opportunity Knocks

Overall reactions to the committee draft of the standard are positive, with IEMA members agreeing that the changes have strengthened the standard and its ability to be embedded in organisations.

“The new edition of the standard will be much more of a challenge for firms, even those that have held 14001 certification for a long time,” says Ledwith. “But the changes are an exciting opportunity that will help to integrate an EMS into an organisation.”

Holman says: “There’s going to be change, but that change is needed. People are worried about how to demonstrate meeting some of the new requirements to auditors, but with some clarifications to the text I think those concerns will be eased.”

The next meeting of the ISO working group revising 14001 will take place in Botswana at the end of June 2013, and will discuss reactions to the committee draft from across the world. All potential amendments will be examined and a second committee draft is expected to be published later in the year. ISO member states will then be balloted. The final standard is due to be published in 2015.

Via The Environmentalist, IEMA.



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