Following the publication of a second draft of the revised 14001 standard, Martin Baxter explains what the new proposals mean for practitioners
Significant changes are proposed in the latest draft of ISO 14001, the international environment management systems (EMS) standard. Given that more than 285,000 organisations in 167 countries are certified against its requirements, and many others use 14001 without going for certification, the changes have the potential to make a positive difference on a global scale.
The big picture
The revision to 14001 needs to be considered in a broad economic and environmental context - particularly as the new standard will not be published until 2015 and will remain in use until the mid-2020s. The economic issues are pretty straightforward: 14001 has to help organisations cut costs, improve productivity, capitalise on business opportunities, maintain and enhance brand, and reduce risks. Of course, if it did not already support organisations to achieve this it wouldn't have achieved the take-up it has, but it must now help users to up the pace in all of these areas.
The environmental context is changing, particularly when considering how the environment can affect a company's ability to create value in the long term. More organisations are seeing the benefits of taking a longer-term view on the way that the environment will shape and influence their future. In revising 14001, the environment profession needs to ensure that, alongside "fixing" problems with the current standard, we also focus on the environmental issues that businesses will be facing in 2020 and beyond.
IEMA has been at the forefront of the revision, engaging members at all stages and reflecting their views and experiences in national and international meetings. It has been a real bottom-up process of listening to individual members about what works well and what needs to be improved; carrying out membership-wide surveys to get a broad perspective; and then clearly articulating that position. This level of interaction not only gives the ISO working group developing the revised standard a fantastic insight into practitioners' views, but also confidence that it is focusing on the key issues.
Strategic direction and leadership
To ensure the integration of environmental considerations into organisational decision-making, IEMA members were clear (95% support) that the revised standard must make stronger links between the EMS and an organisation's overall strategy. ISO's new high-level structure for management systems standards is being used as the basis for the revised 14001 and new sections on "context" and "leadership" provide the basis of achieving this. There are new requirements around "understanding the key internal and external drivers", for example, which will provide a high-level strategic understanding of important issues relating to managing environmental responsibilities.
Also, a new requirement to "understand the needs and expectations of interested parties" brings in the views of stakeholders, which are crucial in determining the scope of the EMS, particularly to develop criteria for evaluating environmental aspects and organisational risks and opportunities.
The revised draft's new section on leadership has been received positively by IEMA members. There are three key points to note with this section. First is the requirement that environment management is integrated into core organisational processes. This is vital to ensuring that environment management is not a marginalised activity, but sits at the heart of the organisation. Second is the requirement that environmental performance is considered in the organisation's strategic planning process. Finally, there are amendments to the requirement for top management involvement in the EMS.
Although the definition of top management - those that direct or control the organisation at the highest level - recognises that one of their powers is to delegate authority, IEMA members concluded that it would be perverse for the standard to include requirements on top management only for them to be delegated. The latest draft of the standard closes this loophole by preventing top management delegating elements of the EMS, such as setting the environmental policy; allocating resources, roles and responsibilities; and undertaking the management review.
Risks and opportunities
In the past, the focus of 14001 has largely been on managing and improving the environmental impacts of an organisation. Increasingly, however, businesses are managing the impact of a changing environment on the organisation itself, such as through adapting to climate change and to issues around resource security and availability. IEMA members surveyed on whether 14001 should consider the environment's impacts on businesses voted 86% in favour. Such an approach has now been incorporated into the revised draft.
A core element of every EMS is the environment policy and the development of a system to implement the policy's commitments. While the current edition of 14001 requires users to commit to being legally compliant, to prevent pollution and to continually improve their EMS, the revised draft adopts a broader approach. The commitment to prevent pollution, for example, is strengthened by another to protect the environment. The new draft suggests that organisations could do this by ensuring sustainable resource use, mitigating against climate change or protecting ecosystems. In addition, the draft standard states that environment protection commitments must be specific to the organisation's situation, which should mean that environmental policies that simply copy out the three core requirements from 14001 will be things of the past.
The most difficult and protracted issue in developing the revised draft has been the section on "risks and opportunities", particularly the relationship between generic business risks and opportunities and an organisation's environmental aspects and compliance obligations. It is not surprising that introducing the term "risk" into an EMS standard poses questions about the link between risk and environmental impact. The addition of the term "opportunities" also implies a certain expectation, or perception, of how people are expected to understand risk.
The definition of risk included the standard ("the effect of uncertainty") is mandated in the text of ISO's high-level structure, and includes a note that the outcome, consequence or effect of uncertainty can be negative or positive. Alongside the implication that a risk may be a threat or an opportunity, the revised 14001 highlights that the uncertainty associated with a potential consequence can vary between high ("unacceptable/critical") and low ("insignificant/negligible"). Although this is understood by risk specialists, it is less recognised in environment management, where risk is more likely to be associated with negative implications, such as loss, damage or harm.
The risks and opportunities section in the second draft of 14001 has been completely reworked, reordering the text and setting out a more defined process. Feedback from IEMA members suggests that the requirements codify what some practitioners are already doing in a more prescriptive way, while for others the new approach will require additional work to relate environmental aspects to business risks and opportunities. It is clear, however, that the definition of risk needs more work.
Value chains and compliance
There is widespread recognition that taking a holistic perspective to environment management across the whole value chain helps to identify business and environmental improvements that might not otherwise be obvious. More than 80% of members who responded to an IEMA survey on 14001 stated that the revised edition should place greater emphasis on managing impacts across the lifecycle of products and services, as well as their supply chains.
Again, this section of the standard has been reworked since the first draft. Amendments have been made to simplify the text and provide greater clarity on what is required. The key change is the focus on significant environmental aspects, risks and opportunities that the organisation can control or influence. Under the new draft of the standard, where companies can exert such control or influence environmental requirements must be specified for the procurement of goods and services, and integrated into design and development/change programmes.
Another alteration in the second draft, has been the introduction of the term "compliance obligations" to replace "legal requirements and other requirements to which the organisation subscribes". Compliance obligations are those requirements with which an organisation has to, or chooses to, comply. These include environmental laws, regulations and permits, as well as contractual requirements, voluntary codes and industry standards. The requirements on the evaluation of compliance have also been extended in the revised draft when compared with the existing standard. An organisation must now specify the frequency under which it will evaluate compliance, as well as maintain knowledge and understanding of its compliance status.
Communications and capacity
External and internal communications is another area that has been amended in the latest draft. The most significant change is the requirement for an organisation to ensure the quality and credibility of environmental information it communicates. This internal assurance process should enhance the reliability and consistency of externally reported performance data, including that required for regulatory purposes.
Ensuring that the content of the revised 14001 captures the essential elements of an effective EMS for the 2020s is clearly important. The real challenge, however, will be in implementation, both within organisations and by third-party auditors.
The proposed changes are significant, and will require a much broader application of environment management throughout an organisation as it becomes integrated into core business processes. Ensuring that those with EMS responsibilities have the skills and capabilities to implement the new requirements will become an increasing focus of IEMA's work. So too will be the support offered to ensure everyone in the organisation can play their part, as the Institute rolls out its "all jobs greener" qualifications with City & Guilds.
More information is available at iema.net/iso14001.
