The Role of National Standards Bodies and Key
Stakeholder Groups in the ISO/TC 207
Environmental Management Systems Standards
Development Activity
Prepared for:
U.S. EPA/OPPT
Prepared by:
ICF Incorporated
3 September 1997
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CONTENTS
, Page
I. INTRODUCTION AND PURPOSE .... !
II. BACKGROUND ON ISO/TC 207 ; 2
HI. METHODOLOGY . 8
1. Identify Data Requirements and Sample Base 8
2. Review of Secondary Materials 10
3. Primary Research t *-\
4. Summary and Analysis **
IV. FINDINGS 12
1. ' Type of Member Body and Mandate I2
2. Relation to Environmental Regulatory Authority 13
3. How Participation is Structured 15
4. Head of Delegation 17
5. National Committee Balance » 19
6. Government Participation 20
7. Industry Participation .. 22
8. NGO Participation .... 23
9. Other Participation 25
10. Process for National Adoption of ISO Standards 26
11. Likelihood of Citing in Regulation 28
12. Types of Government Support for Voluntary Standards ,.., 29
V. CONCLUSIONS ...'... 32
ANNEX A - COUNTRY PROFILES
'
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I. INTRODUCTION AND PURPOSE
As part of its overall mission of protecting human health and the environment, the U.S.
Environmental Protection Agency (EPA) is a participant in multilateral efforts to develop
voluntary standards for environmental management and performance. To provide a focus for this
work, the EPA, in 1993, formed the Voluntary Standards Network (VSN), a cross^Agency
mechanism designed to coordinate EPA's interests and participation in the development of
international voluntary standards. Since that time, the Network has taken on the additional role of
acting as a vehicle to promote Agency-wide objectives within the voluntary standards
development arena. .
' A key initiative of the Voluntary Standards Network has been participation in the efforts of the
International Organization for Standardization (ISO) Technical Committee 207 (ISO/TC 207),
the committee charged with developing a series of standards on environmental management and
related tools known as the ISO 14000 series. To ensure the ongoing effectiveness and
improvement of its participation, the EPA is interested in understanding how other governments,
national standards bodies, and key stakeholder groups have participated in the development of
these international standards, as well 'as how, these standards are used hi other countries.
.'-,/'_' ;;
The objectives of the EPA are to better understand: .
the role of national standards bodies and their relationship to governmental agencies;
the participation of industry, non-governmental organizations (NGO) and others in the
development of international voluntary standards;
the process of adoption of ISO standards as official national standards or regulations; and
the ways in which these standards will be recognized or used by other governments. .
To meet these objectives, we have conducted research into how the various stakeholders have
participate in the ISO process. This report is a result of that research. In it, we have looked in
. general at how the ISO process works and then in more detail at an example of the ISO process
hi action, that is, the activities of ISO/TC 207. We have collected information from and about the
participation of 27 of the most active participants in this activity. The participants studied also
represent a geographical balance. This information has resulted in a number of findings and
conclusions that can provide a basis for EPA to better understand how to establish a leadership
role in representing the federal government with respect to voluntary standards. It may also be
used to establish multilateral communications among all interested stakeholders.
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II. BACKGROUND ON ISO/Te 207
The ISO environmental management system standards originated in several inter-related
activities. First, the Business Council for Sustainable Development, a group established to
provide business input into the 1992 United Nations Conference on Environment and
Development (UNCED) held in Rio de Janeiro, was instrumental in promoting the concept of
voluntary consensus standards as a means to improve environmental performance. Second, the
preparatory meetings for the Rio Conference discussed the utility and effectiveness of - .
environmental management standards. Third, voluntary standards and their place in the
international system of trade were deliberated at the Uruguay Round of GATT. Fourth,
individual companies, increasingly affected by conflicting pressures from governments, and
environmental and consumer groups,.were seeking standards and related conformity assessment
programs as a means of establishing accepted norms.
In June, 1991, at the prodding of the Business Council for Sustainable Development, the ISO and
its sister body the IEC (the International Electrotechincal Commission) jointly established an ad
hoc group the Strategic Advisory Group on the Environment (SAGE). This group had two tasks:
1) to provide'input on the potential role of international standards into the UNCED process, and
2) to develop recommendations for the Technical Management Boards of the ISO and the IEC on
whether international standards should be developed in this area.
The SAGE deliberations lasted until December 1992, at which time the Group submitted its
report and recommendations to the ISO and the IEC. SAGE recommended that the ISO establish
a new technical committee to develop standards in the following areas:
1. Environmental Management Systems (EMS)
2. Environmental Auditing (EA)
3.. Environmental Performance Evaluation (EPE)
4. Life Cycle Analysis (LCA) .
5. Environmental Labeling (EL)
6. Terms and Definitions (T&D)
7. Environmental Aspects of Product Standards (E APS) ..
In January of 1993 the Technical Management Board of the ISO.approved the SAGE
recommendations and established a new technical committee, TC 207, to manage the.
development of these standards. In March of 1993, the Standards Council of Canada (SCC) was
awarded the management of the TC 207 Secretariat. The Canadian Standards Association took
on the task of administering the secretariat on behalf of the Council.
TC 207 established a work plan that now contains 19 items.
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Exhibit 1
ISO 14000 Series
Designation .
ISO 14001
ISO 14004
ISO 14010
ISO 14011 .
ISO 140 12
ISO 14015
ISO 14020
ISO 1402.1
ISO 14022
ISO 14023.
ISO 14024
ISO 14025
ISO 14031
ISO 14040
ISO 14041
ISO 14042
ISO 14043
ISO 14050
ISO Guide 64
Title
Environmental Management Systems - Specification With Guidance -for Use
Environmental Management Systems - General Guidelines on Principles, Systems
and Supporting Techniques .
Guidelines for Environmental Auditing - General Principles of Environmental
Auditing . ""-.''.
Guidelines for Environmental Auditing - Audit Procedures: Auditing of
Environmental Management System , .
Guidelines for Environmental Auditing - Qualification Criteria for Environmental
Auditors .
Environmental Assessments of Sites and Entities '
Environmental Labels & Declarations - General Principles .
Environmental Labels & Declarations - Environmental Labeling - Self Declaration
Environmental Claims - Terms and Definitions .
Environmental Labels & Declarations - Environmental Claims - Self Declaration
Environmental Claims - Symbols ,
Environmental Labels & Declarations - Self Declaration Environmental Claims -
Testing and Verification Methodologies
Environmental Labels & Declarations - Environmental Labeling Type I - Guiding
Principles and Procedures .
Environmental Labels & Declarations - Environmental Labeling Type III -
Guiding Principles and Procedures
Evaluation of Environmental Performance
Life Cycle Assessment - Principles and Guidelines
Life Cycle Assessment - Inventory Analysis
Life Cycle Assessment - Impact Assessment .
Life Cycle Assessment - Interpretation
Terms and Definitions : . .
Guide for the Inclusion of Environmental Aspects in Product Standards
3
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By the fall of 1996 the first five standards in the series (ISO 14001, 14004, 14010, 14011, and
14012), those essential to the implementation and auditing of the environmental management
system, were published.
Participation in the activities of TC 207 has been significant. At the first plenary meeting of the
technical committee in June 1993 in Toronto, Canada, well over 200 delegates from more than
30 countries participated. By the fifth plenary meeting, held in Kyoto, Japan in April 1997, more
than 500 delegates from, 70 countries participated. In addition, more than 50 subcommittee and
working group meetings are held each year.
Exhibit 2 lists the countries (with member body in parentheses) who participate in ISO/TC 207
activities. . . .
* There are also 30 liaison members. These are. organizations (rather than countries) that bring
relevant expertise to the table. They can participate folly in all meetings and discussions but
cannot vote. Exhibit 3 lists the organizations that act as liaison members to TC 207. These
members usually represent the larger International industry sector associations, inter-government
agencies, and International NGOs .and ENGOs.
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Exhibit 2
ISCYTC 207 Members
2.
3.
4.
5.
6.
7.
8.
9.
'10. '
.11.
12.
13.
14.
15.
16.
-17.
18.
19.
20.
2.1.
22.
23.'
24.
25:
26.
27. .
. 28.
29.
30.
31.
32.
P- Status
Country & Organization
Algeria, IN API
Argentina, IRAM ,:
Australia, SAA
Austria, ON -
Belgium, JBN
Brazil, ABNT
Canada, SCC
Chile, INN . . :
China, CSBTS
Colombia, ICONTEC
Cuba,NC .
Czech Republic, COSMT
Denmark, DS
Equador, INEN
Egypt, EOS . -
Finland, SFS
France, AFNOR
Germany, DIN
India, BIS , .
Indonesia, DSN
Ireland, NSAI
Israel, SII .
Italy, UNI
Jamaica, JBS '
Japan, JISC
Kenya, KEBS
-Korea, KBS .
Malaysia, SIRIM . .
Mauritius, MSB
Mexico.DGN
Mongolia, MISM
Netherlands, NNI
O- Status
Country & Organization
Barbados, BNSI ,
Botswana, BWA
Costa Rica, INTECO
Croatia, DZNM
Estonia, EESTl
Ethiopia, EAS
Greece, ELOT
Hong Kong, HKPC
Iceland, ICS
Libya, LNCSM
Lithuania, LST .
Poland, PKNMIJ
Portugal, IPQ .
Slovakia, UNMS
Slovenia, SMIS
Sri Lanka, SLSI
Vietnam, TCVN '
Yugoslavia, SZS
'
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Exhibit 2 (continued)
ISO/tC 207 Members
P - Status
O- Status
Country & Organization
Country & Organization
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
New Zealand, SANZ
Norway, NAS
Philippines, BPS
Romania, IRS
Russian Federation, GOST
Singapore, SISIR
South Africa, SABS
Spain, AENOR
Sweden, SIS
Switzerland, SNV
Tanzania, TBS
Thailand, TISI
Trinidad and Tobago, TTBS
Turkey, TSE
Ukraine, DSTU
United Kingdom, BSI
Uruguay, UNIT
USA, ANSI
Venezuela, COVEMN
Zimbabwe, SAZ
P - Participating member
O = Observer member
Note I: This list is correct as of Feb. 21, 1997. Changes occur frequently.
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Exhibit 3
Liaison Members
1.
2.*
3..
4. -'..
5.
6.
7.. ,
8.
9.
10.
11.
12..
' 13.
14.
15. '
16.
17.
18.
19.
20.
21. ,
22.
23.
24.
25.
26.
27.
28.
29.
30.
Organization
Asian Productivity Organization
Confederation of European Paper Industries ; . .
Consumers international --'..
Directorate General of European Commission ' ;
Environmental Defense Fund . ?
European Apparel and Textile Association : .
European Chemical Industry Council
European Environmental Bureau
European Manufacturers of Expanded Polystyrene
Forest Stewardship Council
Friends of the Earth International
International Academy for Quality
International Chamber of Commerce
International Council on Metals and the Environment
International Federation of Consulting Engineers
International Federation of Organic Agricultural Movement
International Institute for Sustainable Development
International Iron and Steel Institute
Industrial Minerals Association
International Network for Environmental Management
International Primary-Aluminum Institute
International Trade Centre
Organization for Economic Cooperation and Development
Sierra.Club .
United Nations Conference on Trade and Development
United Nations Environment Program . .
United nations Development Program
World Wide Fund for Nature
World Federation of Sporting Goods Industry
World Trade Organization
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III. METHODOLOGY
To generate and evaluate information on role of National standards bodies and key stakeholder
groups in the ISO/TC 207 environmental management systems standards development activity,
we followed a methodology consisting of four phases.
1. Identify Data Requirements and Sample Base
To streamline the research process, we began by combining the information requirements of the
scope of work for task 3.1 (Review the Involvement of Government Agencies of Other ISO
Member Nations in Developing and Using Voluntary Standards) and task 3.3 (Review the Role
of the Private Sector in Developing Voluntary Standards in other ISO Member Nations; in
Developing and Using Voluntary Standards). To address the latter we expanded the scope of our
research on the role of the private sector to include environmental non-governmental .
organizations (ENGOs), and professionals such as academics and consultants. We then
developed a template that listed the information that we would seek from the subject countries. .
This is presented in summary form below. ,
Exhibit 4
Research Template
1. Country
2. Member Body
3. Address
4. ISO/TC 207 Contacts
Standards Body Contact
Government Contact-
General Information
1. Type of member body government
of private sector
legal mandate or authority
2. Relation of member body to
environmental regulatory authority
TC 207 Participation
How participation is structured
4. How is head of delegation chosen
5. Is there balanced representation on
' national ISO committee
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Exhibit 4 (continued)
/Research Template
6.
Is government on the committees:
how are they selected
from what ministries
what is their relative level of
influence
7.
Is industry on the committees:
how are they selected
what is their relative level of
influence.
&. Are environmental groups on the
committees:
how are they selected
what is their relative level of
influence
9.
Are other specialists on the
committees (scientists, academics,
consultants):
how are they chosen
what is their relative level of
influence
,10-
11.-
12.
13.
14.
Process for national adoption of
ISO standards . .
Frequency of ISO standards qited
in regulations
Why are they cited
Likelihood of ISO 14000 being
cited in regulation
Types of government support for
ISO 14000:
used in government procurement
subsidies for implementation/
1 certification
| subsidies for training
1 regulatory or permitting relief .
~* ; - ''
- . . ...
,
'.'
- . .
. ' . .
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To populate the database With information we selected those countries, out of the over seventy
countries that have participated in the deliberations of ISO/TC 207, which have been most active
and for which information was most likely to be available. Our first screen was to include only
P' (participating) members, that is, members who agree to participate in committee and working
group meetings. 'O' (observer) members receive the documents of the committees but are not
obliged to participate in the committee and working group meetings. As a consequence, their
influence during the development process is less than that of 'P' members.
Of the ISO/TC 207 'P' members there are several who participate only nominally/They send
few if any delegates to subcommittee or working group meetings and often only one delegate to
the annual plenary meeting. Having reviewed recent committee attendance lists and with a view
to establishing regional balance we identified the following 32 participants:
Eur0pe South America Asia and the Pacific.
1 Austria ' I- Argentina 1. Australia
2. Belgium 2. Brazil 2. China
3. Czech Republic 3. Chile . 3. Indonesia
4. Denmark 4: ^
5 prance ' North and 5. Korea
6 Germ-any Central 6. Malaysia
7 Ireiand America 7. New Zealand
7 itaiy , and the 8. Singapore
8. Netherlands Caribbean 9. Thailand
9,. Norway '
10. Spain ' 1- Canada Africa
11. Sweden 2. Jamaica .L South Africa "
12. Switzerland 3. Mexico 2. Zimbabwe
13 UK 4. Trinidad & Tobago
Several countries did not respond to our- several requests for information. These countries were
Belgium, Denmark, Mexico, Trinidad and Tobago, and France. . .
We therefore developed profiles of 27 countries.
The United States was not included in this sample because it is dealt with more fully in the other
Task 3 reports.
2. Review of Secondary Materials
Having identified the information requirements and the sample base, we first reviewed all
available secondary materials. These included any materials published by the national standards
bodies themselves (brochures, newsletters, information bulletins, articles), as well as information
available on web sites. '
1-0
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3. Primary Research
We then contacted the national standards bodies by fax and e-mail in an effort to fill in the
'information gaps remaining after the secondary materials had been reviewed. Unless there was
an immediate and helpful'response, we followed up each fax and e-mail with a telephone call. In
almost every case a telephone follow-up was required. In many cases the national 'standards
bodies were also the sole or best source of secondary materials. Secondary and primary research
thus tended to be conducted simultaneously. During the phone calls, we indicated that we were
doing research bn behalf of the EPA. Representatives of most countries were very cooperative
and willing to share information and contacts. .
4. Summary and Analysis
The final step was to review the information and to prepare this summary and analysis. We put
the information obtained from primary and secondary sources into a consistent format to
facilitate analysis and reporting. We developed findings for each data field. We then develop a
number of conclusions based on an analysis, of all data. Detailed country by country results are
provided in Annex A.
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IV. FINDINGS
1. Type of Member Body and Mandate
There can only be one ISO member body per country. The ISO stipulates neither the
organizational structure nor the source of the mandate for these member bodies. National
member bodies must, however, be able to demonstrate that their delegations represent the range
of national views. , .
i, * _
Our research suggests an interesting diversity with respect to the manner in which the member
bodies are constituted. There is a full range of types of organizations. We have divided them into
four types, ranging from fully governmental to fully separate from government.
Exhibits
Member Body and Mandate
Government
Agency
China
Ireland
Jamaica
Japan
Korea
Malaysia
.Singapore
Thailand
.
Arms-Length
Government
' Agency
Canada - Federal
Crown Corporation
.Czech Republic
Private Sector With
Government
Mandate
Argentina
Australia
Austria
Brazil
Indonesia
Italy
Netherlands
New Zealand
Spain
South Africa
Sweden
Switzerland
U.K.
Zimbabwe
Private Sector With
No Government
Mandate
Chile
Germany
Norway
i.
Regardless of whether the member body is fully governmental of private sector there is almost
always government involvement in the establishment of the mandate or authority to act.. Only.
three of the member bodies surveyed claim to receive their mandate form their member or
sources other than government. Of these three, Chile, which claims to have a fully private-sector
standards body, also indicates that six of its seven standards body council members are
12
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government officials. Germany and Norway the other two countries that claim to have
independent mandates do have independently structured standard bodies with independent
governance structures. As members of the European Union, however, they are, to a certain
extent, bound by government policy because of the relationship between their federal
governments and the European standards setting bodies (CEN, CENELEC), which receive their
direction from the European Parliament. There is always significant government involvement in
a national standards body,
The government agencies receive their mandate directly from the government. Their governance
is also-controlled by government. In many cases, however, there will be advisory councils or the
like made up of experts who represent different interested parties. This is the case, for example,
in Jamaica, Japan and Malaysia. ,
. The member bodies in the two middle columns have government mandates but independent
governance, through a board or council,
A few member bodies, such as the Standards Council of Canada, do not in fact develop standards
.but simply act as central standards accrediting organizations. The actual standards development
is carried out by private sector, standards development organizations. The standards developed
by these organizations are then submitted to the national body for accreditation as national
standards. This is also the situation is the US where ASNI, the ISO member body,, does not
develop standards itself, but accredits standards developed by other voluntary standards
developers such as ASTM, ASQC or NSF as American National Standards (ANS).
In most countries this js not the case. In Germany, in the United Kingdom, in Spain the member
bodies - the Deutsches Institut'fur Normung (DIN), the British Standards Institute (B SI), the
Asociacion Espanola de Normalizacion y Certifacion (AENOR) - are moire typical. They both
manage the development of standards and designate those standards as national standards.
2. Relation to Environmental Regulatory Authority
Although in most countries there is a clear connection to both the regulatory and the honr
regulatory elements of government, the connection to the regulatory element is most often
indirect. . .
13
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Exhibit 6
Relation to Environmental Regulatory Authority
Direct
Indirect - through
participation on governance
bodies or on development
committees
None
China
Argentina
Korea
Australia
Singapore
Austria
Thailand
Brazil
Canada
Chile
Czech Republic
Germany
Indonesia
Ireland
Italy
Jamaica
Japan
Malaysia
Netherlands
Norway
New Zealand
South Africa
Spain
Sweden
Switzerland
U.K.
Zimbabwe
There is always some relation to the government. Where there is a direct link'to a government
agency, it is essentially an organizational link, as in the case of Ireland, where the national
standards body is a government department but operates with considerable autonomy of
governance. It is not a necessary result of this indirect link between government and standards
bodies that all standards become regulation. Nonetheless, this arrangement has the opportunity to
promote a better understanding among regulators of the role of voluntary standards. In addition,
in most cases the direct link from the standards body to government is through an industry or
14
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commerce ministry" and riot an environment ministry. Those standards bodies we have listed as
having a direct link to government are those that are most open to influence by government.
In most cases, the indirect link is achieved.by having members of the environmental regulatory
body sit on the governing council of a standards body and on standards development committees.
. In many cases the indirect relationship is also supported through the funding of the standards
development effort by the environment ministry,
In some instances, such as for example Jamaica, the Minister in charge of a regulated area must
be kept informed of all voluntary standards development activity in his or her area of ^
responsibility, even where there is no direct link between the regulatory body arid the national
standards body. In most cases, the regulatory brancrTwill review a standard to determine whether
it is appropriate for citing in; a regulation.
At the National level it is often possible for a regulatory branch to commission a voluntary «
standards development organization to dfevelop a standard required by legislation. However, a
single country cannot commission the ISO to develop a standard for regulation. There-is a
formalized process for having a new work item approved by the ISO. This process involves the
review and consideration of a formally submitted new work item proposal by other members
bodies. No new work item can go forward without the agreement of at least four member bodies.
So while a country may submit a new work item proposal to the ISO with the intent to cite the
resulting standard in legislation, it may not commission the ISO directly to develop a given
standard. However, they can submit a proposal to develop an international standard.
Also, ISO standards are voluntary, and ISO does not enforce their implementation. Some ISO
standards - mainly those concerned with health, safety or the environment - have been adopted
in some countries as part of their regulatory framework, or are cited in and provide the technical
basis for legislation. However, such adoptions are sovereign decisions-by the regulatory
, ' authorities or governments of the countries concerned. ISO itself does not regulate or legislate.
3. How Participation is Structured
There are three levels of ISO committee: . ' '
. the.technical committee (TC), , , , .
the,subcommittee (SC), ,
the working group (WG).
At the TC and SC levels decisions are made on matters of policy and strategy concerning,
respectively, a standards series as a whole and a specific subject area. The working group level is
where the documents actually are researched and drafted.
With few exceptions, the national committees or groups established to manage participation in a
specific ISO standard or set of standards mirror the committee structure of the international
15
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committee. These national committees or groups are most often administered by the national
standards body or a standards developing organization designated by the national standards body.
In ISO/TG 207 the most active countries have committees that correspond to all three levels of
ISO committee (TC, SC, WG). Less active countries will mirror only the top or the top two
levels or will selectively establish mirror committees depending on their interests. Not all
countries choose to be active in all committees and working groups. Accordingly, although the
national committee or group structure tends to mirror the ISO structure, it is not always the case
that there is a national committee or working group for every ISO committee or working group.
Also the greater the interest and involvement in a national committee, the more likely it will be
that a country will participate at the working group level. The countries that participate most
actively will obviously have the most influence.
Some countries however, do not have national committees or groups. Chile is a good example of
' this end of the spectrum. They have a series of already established national sector committees
from which they select delegates to attend the ISO/TC 207 meetings.
In many cases, the national committees or groups that support international work serve double
duty and act as the national committee or group to support national work. Thus, they participate
in the international meetings and provide the conduit, if not the mechanism, for adopting the
International standards as national standards.
The chart below provides an indication of the relative level of influence of national delegations
participating in ISO standards setting activities.
Exhibit?
Participation
Participate in all or
close to all of the
committees and .
working groups
Australia
Canada
Germany
Japan
Korea
Netherlands
Norway
New Zealand
Sweden
U.K.
USA '
Participate in 75% or
more of the committees
and working groups
Austria
Brazil
Indonesia
Ireland
Malaysia
South Africa
Spain
Switzerland
Participate in 50% or
more of the
committees and
working groups
Argentina
Chile
Italy .
Jamaica
Singapore
Thailand
Participate in less
the 50% of the
committees and
working groups.
China,
Czech Republic
Zimbabwe
16
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Note 1: Participation means attending international meetings and actively contributing to-document
development. Countries with apparently low participation rates may still have very active national .
committees.
Note 2: The close to forty countries who are either P or O members who are not part of the sample base
for Ms study all participate in less the 50% of the committees and working groups. In the case of well
' over twenty countries, participation, is limited to the annual plenary meeting.
4. Head of Delegation
The way in which the head of the ISO/TC 207 delegation is chosen by varies considerably along.
a spectrum from appointment to election. There is a high correlation between the members with a
high level of involvement and' sophisticated national committee or group structures, arid the
members that select or elect their own head of delegation. . ' ,;
Exhibits
Process for Selection
Appointed
Selected
Elected
Argentina
Australia
Austria
Chile
Brazil
Germany
Czech Republic
Canada
Italy
Indonesia
Singapore
Japan
Ireland
Korea
Jamaica
Indonesia
South Africa
Netherlands
Spain
Norway
U.K.
New Zealand
Sweden
Switzerland
Thailand
Zimbabwe
Note: Appointed means the national member body identifies and appoints the head of delegation,
often based on advice from the members. Selected means the member body plays a role by
nominating or. identifying the head of delegation who is then endorsed or ratified by the
members. Elected means that the members initiate the process by making nominations and make
the selection through an elective process. . ,
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There is also a high percentage of heads of delegation who come from the standards bodies.
themselves. Most often, the reason for a standards body representative taking on the role of head
of delegation is so that a balanced national view can be presented at plenary meetings. The
standards body representative is usually not a stakeholder per se. Rather he or she facilitates the
development of positions among stakeholders and administers the process. Among the countries
that are less active participants in the process, the likelihood of the head of delegation being a .
representative of a standards body increases.
It is infrequent, yet not uncommon, for a government representative to be chosen head of
delegation. This has happened, for example, in the United Kingdom. The one noticeable absence
in our review, is a head of delegation from a non-governmental organization.
Exhibit 9
Source of Heads of Delegation .
Country
Argentina
Australia
Austria
Belgium
Brazil
Canada
Chile
China
Czech Republic
Germany
Indonesia
Ireland
Italy
Jamaica
Japan
Korea
Malaysia
Netherlands
New Zealand
Norway
Singapore
South Africa
Spain
Sweden
Switzerland
Thailand
UK
USA
Zimbabwe
Head of Delegation
standards body
standards body
industry
standards body
standards, body.
practitioner (consultant)
standards body
government
standards body
standards body
Standards body
standards body
industry
standards body
practitioner (academic)
standards body
standards body
standards body
industry
industry
standards body
standards body
standards body
government
industry
government
government
standards body/other
standards body
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5. National Committee Balance .
ISO requirements for participation are stated in ISO Directives, Part 1, Procedures for the
Technical Work, 1995. In clause 1.7.1 it states: . , .. - .
National bodies have the responsibility to organize their national input in an efficient
and timely manner taking into account all relevant interests at their national level.
The directives do not .define how all relevant interests are to be accounted for; nonetheless, many
national standards bodies have rules for balance that they apply to meet this requirement. The .
first step is usually to categorize the interested parties. The secdnd step' is to establish some, sort
of. rule for balance. Typically, a standards committee is composed of four or five categories of
members. In the environmental management systems area these are typically the following:
government . ^ ;"'. '
industry /. .- - '
practitioners or users (professionals, academics, consultants) .-'.-..
non-governmental organizations (environmental groups, consumer groups)
All members are volunteers. To obtain balanced membership, the national member body will
' usually publicize the activity and solicit volunteer participation. In practice, the member pool is
usually populated in three ways: - . .
1. The member body goes to representative government departments or ministries, and to
representative industry, business, professional, environmental, and consumer associations
and asks them to identify and nominate suitable members.
2. Existing committee members or member body staff identify and nominate members as a
resiilt of personal contacts and sector knowledge. . . ...
3. Interested individuals hear of the activity and put themselves forward.
', Accounting for all interests is accomplished in one of two ways: ;
.1. by balancing the national committees, or
2. by using a process of open public canvassing. >
In some countries, both processes are used.
Balancing national committees is usually achieved by defining how many^people from any given
category may sit on. the committee. There are usually no hard and fast rules about numbers. .The
major concern is that no one group can dominate. In Canada, for example, the rule of thumb is
. that the number of members hi the category with the largest number of members (usually
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industry-) cannot be'larger than the number of members in the sum of the smallest two categories
(usually government and NGOsj. Thus, no one group will have more than 50% of the vote.
Where there is no similar rule of thumb for committee or group balance, the requirement for
'taking into account all relevarit interests is often dealt with through a process of public
canvassing. In other words, at various stages in the development process the draft standard is
made available to the public for review and comment. The effectiveness of this process is
dependent upon the public coming forward. Regardless of whether or not there was actual
participation by representatives of each category, this canvassing process allows the member
body to claim that the requirement has been satisfied (because the document was made
available).
While most countries participating in ISO/TC 207 declare that they have balance in principal, iff
fact, very few seem able to demonstrate that they have achieved balance (see the tables attached,
and the discussion in sections 6-9 below).. .
,6. Government Participation
Government representatives in-the activities of ISO/TC 207 come from 'a wide variety of
Ministries and Departments. The largest numbers are.provided by environment and industry or
commerce departments. The list below represents the general categories identified in the study.
Environment
Natural Resources and Sustainable Development
Environmental Protection Department
Ministry of Environment
Lands and Water Resources
Industry ,
Mines .
Energy . .
Industry, Science and Tourism
Science and Technology .
Industry and Trade
Agriculture and Fisheries
i i
i .. . . ...
Trade and Commerce . . . .
,.».,- ' . -s
Commonwealth Department.
Foreign Affairs
International Development
Domestic Trade and Consumer Affairs ' , .
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.Infrastructure
Public Works - '-...;'
Housing
Rural and Urban Development /' '.
. Health and Welfare - .- - , .-.-....
General or Inter agency . , . r
Office of the President
Inter -Departmental Liaison
Interagency Environmental Standards Group '..'..'
The government participates in standards development activities, in some capacity in all
countries.. There are, however, differences in level of influence. Where there is substantial
government influence, it arises not because of,the numbers of government people involved but
rather because of the nature of the relationship between government arid standards setting
.activities. .
Exhibit 10
Level of Influence-Government .
High Influence >
Chile
China
Jamaica
Japan ., ,
Malaysia
Netherlands
Singapore
Spain
''
- .
'".'.
Equal Voice
Australia
Austria
Brazil
Canada
Germany .
Indonesia
Ireland
Italy
Korea
New Zealand
Sweden
Switzerland
Thailand
U.K.
Zimbabwe
Low Profile
Argentina
Norway
South Africa
i
' -
21'
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The nature of the role played by government generally appears equal to that played by any other
interest group. Government representatives take, leadership roles within the national committee
system, they vote, and they advocate positions based on the nature and source of their
participation.
7. Industry Participation
Many national standards bodies and standards developing organizations work through industry
sector associations, federations of industry, and chambers .of commerce. These are the bodies that
have traditionally brought industry sector experts together to establish and work toward common
objectives. Thus, industry representation often has a cohesiveness lacking in other categories of .
participants. .
The dominant industry sectors involved in ISO/TC 207 include the following: ;
chemicals metal fabrication .
plastics electronics -
timber ' information technology
forestry manufacturing
oil and gas heavy transport
utilities automotive
mining packaged goods
These sectors are those that are most international in scope and that are interested in
standardization as it affects their international trade situations. They are also heavily resource-
based and manufacturing-oriented. In other words, the sectors-that have decided that it is worth.
the investment to participate voluntarily are those traditionally most affected by environmental
regulations and those who 'might expect to benefit from voluntary standardization.
These sectors are also those in which individual facilities are most often large-scale enterprises.
Small-scale enterprises are underrepresented. Although some countries claim that small and
medium sized enterprises (SMEs) are represented indirectly through industry associations, it is
also the case that indirect representation is never as effective as direct representation.
Most countries indicate that in principal, the level of industry influence is equal to that of other
stakeholders. However, this is often qualified by saying that the fact that they have greater
numbers often increases their influence. In Brazil, for example, 60% of the committee members
are from industry, yet they state that all interested parties have an equal voice. As the table below
indicates, industry often has a high level of influence and at the very least an equal voice. It .is
apparent that industry feels comfortable in the international standards setting forum and takes
advantage of its strong position. : .
Representatives of several countries, such as'Germany and Japan, did not comment on the
relative influence of the various interest groups.
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Exhibit 1.1.
Level of Influence - Industiy
High Influence
Equal Voice
Low Profile
Argentina
Australia
Chile
Austria
Japan
Brazil
Malaysia
Canada
Netherlands
Germany,
.Norway
Indonesia
South Africa
Italy
Singapore
Jamaica
Spain
Korea
Sweden
New Zealand
Switzerland
Thailand
U.K.
Zimbabwe
8. NGO Participation
National member bodies do not have a good record of involving non-governmental organizations
- most specifically, environmental and consumer groups - on their national ISO/TC 207
committees or groups. As the chart below shows, only about half have any representation at all. .
Of those that do, no one was willing to claim that the influence was high. Several of those who
claimed thatthe NGO's have an equal voice have made this claim in principle rather that
demonstrating mat it is practiced by providing names and numbers of participants. .
Several reasons are offered: .
it is a volunteer activity and NGOs lack funds to participate,.-
they have been invited and are welcome but have declined to participate, or
they can participate in principle but - for whatever reason - they are not active at present.
The respondent for Korea claimed that there are no known environmental groups in Korea. The
respondent for Singapore said something similar and defended it by saying there are only 3
million people in Singapore.
It appears that while industry is familiar with and comfortable with this forum, NGOs are either
not familiar or not comfortable with it. For some NGOs the issue has to do with process. They
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are reluctant to participate in a forum in which they feel the process does not provide them with a
full voice In the case of ISO this is as much perception as fact. It has, however, had an effect on
participation levels. For other NGOs it has to do with a fear of being co-opted. To participate
means to add the weight of your voice and your constituency. There is the fear that their name
might be attached to something with which they would not feel comfortable. This argument is
often seen to be disingenuous, because if you do not participate you have no opportunity to
influence the outcome in a way that would be acceptable.
Exhibit 12
Level of Influence - NGOs
, High Influence
*
Equal Voice
Argentina
Australia
Canada
Indonesia
Ireland
New Zealand
Thailand
U.K.
Zimbabwe
-
Low Profile
Jamaica
Netherlands
Norway
Spain
Little or No
Participation
Brazil
Austria
Chile .
Germany
Italy
Japan
Korea .
Malaysia
South Africa
Singapore
Sweden
Switzerland
Cle"arly an international forum such as the ISO must provide the necessary incentive and comfort
level for the affected parties to participate. While the national member bodies have not been too
successful in including NGOs in their national committees or groups, there has nonetheless been
a level of highly visible participation by the NGO community. For the. most .part, they have
chosen to participate as Liaison organizations. As Liaison organizations they can participate in
any committee or working group. They do not, however, have a vote. Strategically, this can be an
acceptable position. From this position an NGO can state that it participated and toed to
influence the outcome but that it did not have a vote and so cannot be held accountable. While .
this allows for a certain level of participation by NGOs, it does not achieve the desired end,
which is participation with accountability. ...
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The NGOs who participate in ISO/TC 207 as Liaison Members include: ; '
Consumers International '..'." ,' . ,
Environmental Defense Fund
European Environmental Bureau . . ' .
Forest Stewardship Council ' ' .
Friends of the Earth , ( , . ,
International Federation of Organic, Agriculture Movement ;
International Academy for Quality ' ,
International Institute for Sustainable Development -'..',
International Network for Environmental Management
.Sierra Club ' ' ,
World Wide Fund for Nature /
9. Other Participation '....',
There is also, significant participation in ISO/TC 207 from other participants, mostly consultants
and academics. The participation from consultants comes mostly from the more developed and
industrialized countries. From-the economies in transition and the developing countries there are .
more likely to be academic participants than consultants.
There are few countries where there is no participation from this group. The group has less
influence than industry or government but more than non-governmental organizations. In
addition, most often scientists, academics, and consultants participate on committees to
contribute a specific expertise.-They do not usually have a position to advocate in the same way
that industry, government, or the environmental groups do. If they advocate anything, it tends to
be sound science and a systematic approach, as well as the need for international standards in the
first instance. . , ' ;
25.
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Exhibit 13
Level of Influence - Consultants and Academics
High Influence
Equal Voice
Low Profile
Netherlands (for LCA)
Australia
Argentina
Austria
Chile
Brazil
Italy
Canada
Norway
Germany
South Africa
Indonesia
Spain
Ireland
Switzerland
Jamaica
Japan
Korea
Malaysia
Netherlands
New Zealand
Singapore
Sweden
Thailand
U.K.
Zimbabwe
10. Process for National Adoption of ISO Standards .
In accordance with WTO agreements, it is the policy of most countries to adopt international
standards wherever possible. There is a definite trend toward increased adoption of international
standards. The opposite side of this coin is that fewer national standards are being developed.
Sweden, for example, claims that almost no national standards are. developed any more. The
most common reasons cited for this trend are-increased international standards development
efficiency, the facilitation of trade (because there are fewer national standards to act as trade
barriers), and the decreased duplication of standards.
The process for the national adoption of international standards is, in most cases, similar to the
process for the development of national standards. The process begins by recognizing or
accepting a need. Standards bodies themselves do not generally initiate standards development
projects,They respond to requests from stakeholders. An international standard must be
proposed to and approved by the members. Where a new international standard has been
approve'd as a work item by a committee; a national committee or group, if it agrees, would
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participate in the development of the standard. If it did not agree it can choose to opt out by not
participating in the development process. ,
Once the standard has been developed each member body is faced with the decision of adopting
. it as a national standard. The decision is made using one of two types of process: an
administrative process where a relevant person with authority approves the adoption of the
standard, a more or less paperwork procedure; or a consensus-based process, where discussion on
adoption of the standard goes through a national committee procedure. The administrative
process relies on the consensus achieved during the international standards development process.
Chile, for example, uses a process that is purely administrative. The consensus process is used by
countries who must, for legal or other reasons, treat the adoption of an international standard as
they would the development of a national standard. Even though consensus has been achieved
international, a new consensus must be achieved nationally. When the consensus process is used
there is often the opportunity to make changes, that is^ to adopt an international standard with
national amendments'. This opportunity does not exist when the administrative process is used.
Members of the European Union use a hybrid of the consensus and administrative processes.
This is because of the existence of the regional standards bodies CEN and CENELEC. The
European regional standards bodies use a balloting process for approval similar to the one used
by the ISO. However, once a standard has been accepted by CEN or CENELEC the members of
"the EU must, by law, adopt it as a national standard, this is accomplished as an administrative .
procedure. The relationship between CEN and CENELEC and the ISO is governed by the
Vienna Agreement. This agreement establishes conditions intended to avoid undue duplication of
effort and provides for a parallel balloting process. Thus, an ISO standard that is simultaneously
approved through parallel ballot by CEN would be adopted by the member countries of the EU
through an administrative process. However, if a member country of the EU wishes to adopt an,
ISO standard that has not been adopted by CEN or CENELEC, it will do so using the consensus
process for national standards development.
There is often a high level of similarity in national consensus processes. This is because of the
standards code of the WTO Technical Barriers to Trade Agreement (TBT) which describes how .
an acceptable standards development program should operate. This code has been especially
useful to developing countries. Developed countries have tended to continue to use their existing
systems and to fine-tune them where necessary to meet the spirit of the TBT. ' .
y ' ' ' ' - - ' ' t
Typically, the national consensus process involves a minimum of three steps.
1., develop agreement among the committee members, «
2. circulate the document for public review, and . . .
3. validate the process. :
Committees of stakeholders develop standards. Very often, the national committee or group is
the same committee or group that supports the international work. However, this is hot always -
the case. In Canada, for example, there are Canadian Advisory Committees (CAC) responsible
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for international work: National technical committees then adopt international standards as
national standards. In reality, the members of these two committees are often, but not always, the
same. In many cases", the international members form the nucleus and other, national, members
are added. . '
National agreement or consensus among committee members is often achieved by ballot. Ballots
must show substantial agreement. In Australia 67% of the committee and 80% of those voting
must support adoption. In Canada all negative ballots must be resolved before the standard can
be approved. The U.K. defines agreement as the absence of sustained opposition. Some countries
do not ballot. Germany, for example, relies on the ability of committee members to reach
agreement without the need for a vote.
The public review process makes a standard available to anyone with an interest. They may -
request a copy and then submit comments. These reviewers do not have a vote. Their comments
must, in most cases, be reviewed by and resolved to the satisfaction of the committee or group.
Reviewers can usually request an accounting of the resolution.
The validation process is a quality assurance mechanism in which a higher level steering
committee or standards policy board reviews the process used for adoption to ensure that all the
rules and procedures were followed. If so, then the standard is recommended for adoptions a -
national standard. Some countries add a' final step to this validation process. Jamaica adds the
step of going to the Minister in the appropriate area of responsibility to gam his or her
concurrence. Japan also involves the relevant minister at this point.
Once an international standard is adopted it is confirmed by the national standards council or
equivalent body, and receives a national designation number. This is usually accomplished by
adding a national prefix to the international designation. Hence ISO 14001 can have a different
designation in every country where it is used.
Organizations based in countries who are not members of the ISO or in ISO member countries
who have decided not to adopt a given ISO standard may still use the standard and may acquire it
directly from the ISO in Geneva. .
11. Likelihood of Citing in Regulation
Similar to the trend of increased adoption of international standards, there is an increased trend to
adopt international standards in regulation, in the place of national-standards. Thus, countries
will cite international standards when there is a need and a national standard does not exist, tew
countries appear to have clear public policy in this area or adequate sources of information on the .
.citing of voluntarily developed standards in legislation and regulation. Canada, the U.K., and.
Australia-are exceptions to this general rule.
When it comes to the ISO 14000 series, there is universal agreement that it is unlikely to be cited
in regulation. However, this does not mean that regulators will not respond to the series in some
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way. There' are a number of options for the recognition of voluntary standards that might be '
classified as follows: v .
cited in regulations,
. covered by an official government position or promotional policy,
recognized by regulators - but not incorporated into regulations, and ,
no action to adopter encourage use of the standard. _
Several countries, such as Argentina and Jamaica, have developed official positions on ISO ,
14000 and are actively promoting it. Many other countries are considering developing such a
policy but have not yet done so. . ' ;
To'have ISO 14001 recognized by regulators but not cited in regulation is an option that is -
proving attractive to many countries. Essentially what this means is that conformance to ISO
14001 will be recognized as providing assurances about compliance with regulatory
requirements and environmental performance but the standard itself is not required by regulation.
Examples of this option will be discussed in more detail in the next section that deals with types
..of government support. In Europe ISO 14001 is already recognized but not required by the '
EMAS regulation because ISO 14001 can be used in partial rulfillment of EMAS under
article 12. .
12. Types of Government Support for Voluntary Standards
We looked at four possible types of government support for voluntary standards.
1. use in government procurement
2. subsidies for implementation or certification
3. subsidies for training
4. regulatory or permitting relief ' (
In addition to these four, we also reviewed government support for, participation in the standards
development process. Governments almost universally, provide this type of support.
Countries have not yet determined how they will use the ISO 14000 series in procurement. This
is largely because the eco-labeling standards have not yet been published and they still have time
to develop policies. No government has formally decided to give preference to companies
registered to ISO 14001. This is partially because of timing. Few companies have yet been
registered. The issue is therefore not imminent. However it may also have something to do with
GATT rules.about the use of technical regulations as non-tariff barriers. If a government makes
ISO 14001 a procurement requirements is it de facto establishing ISO 14001 as a. technical
requirement and therefore a potential NTB? While this interpretation is unlikely since a
procurement requirement does not restrict access.to a geographical market, only to a government
market and that it is therefore a contractual and not an inter-governmental issue, many
governments are still cautious of making ISO 14001 a binding procurement requirement. It is
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more likely to be identified in procurement specifications as an incentive, 'or made a condition
after the point of sale rather than before.
Unofficially, governments who have participated in the standards development process are -
monitoring the type and number of organizations that are being certified. In Europe, ISO 14001
is supported in procurement practices because of the requirements of the EMAS regulation.
Many countries are providing subsidies for implementation support. These are usually of ;one or
more of three types; .
1. providing funds to sector associations to provide programs for their members,
2. sponsoring EMS implementation pilot programs, or
3. grant programs to support individual companies.
At least the following countries are providing implementation subsidies:
Argentina ' Indonesia . Singapore.
Austria Ireland Spam .
Brazil 'Malaysia Sweden
Canada . Norway Thailand
China New Zealand U.K.
A few countries provide some training subsidies or programs. More typically they encourage the
private sector to develop ISO 14000 related seminars and workshops. Also, many standards
bodies develop and deliver training programs as a source of revenue to support standards
development activity.
At least the following governments provide some sort of training support:
Australia ' Indonesia Netherlands
Brazil ' Ireland New Zealand
Canada Japan .
Although many countries are studying and considering some sort of regulatory relief, few have
established programs. When we speak of regulatory relief, we refer to an easing of the
administrative burden of permitting and enforcement activities. This means such things as less
paperwork, consolidated permits or approvals rather than a number small ones, fewer
inspections and visits, and streamlined reporting procedures. Regulatory relief does not refer to a
release from the requirement to meet regulatory performance standards. : . . .
Many countries are looking to a two track or two tier system. One track would offer various
types of administrative relief for organizations that have implemented and been registered to ISO
14001 and another, more traditional command and control track would be available for
companies who choose not to adopt the voluntary environmental management systems approach.
30.
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We have listed a few examples-below of efforts to recognize ISO' HOOK
Australia
In Victoria, NSW, accredited licenses were created by the EPA. If a company meets the
following three criteria then it may qualify for an accredited license that will allow for some'
regulatory relief,'in the. -form of a company having to apply for fewer permits.
'EMS in place ,
Auditing program .
Public participation .',.
Government will monitor companies to ensure that their targets are achieved. If they are not,
the EPA may take the accredited license away and re-apply the normal permitting system to
the facilitv. ' .
Jamaica
In Jamaica, the government will perform less National Resource Conservation Act (NRCA)
monitoring for companies that have implemented ISO 14001. Industry will still have to apply
for the same number of permits. ' "
Japan
Currently, local governments are studying how to introduce the certification of ISO 14000 into
their own regulations in place of the command and control system that is currently used. This
is the dual track svstem similar to the one being discussed in the United States.
Netherlands ,
The Dutch government is stimulating the implementation of ISO 14001 by providing relief in
licensine and enforcement. , - '
New Zealand
New Zealand has initiated a pilot program with Tasman Forestry to determine whether an
EMS prepared by a major business conforms with the Resource Management Act and can
demonstrate an acceptable level of compliance with regional plans. The pilot aims to
determine whether non-resulatorv methods can be used to implement legislated requirements.
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U.K.
In the U.K. the Environmental Agency is encouraged to allow permitting relief to companies
that are ISO 14001 certified.
V. CONCLUSIONS
We can draw the following conclusions from this review.
1. Most National Standards Bodies operate under government mandate.
2. Most National Standards Bodies have independent governance. :
3. Most National Standards Bodies have indirect ties to regulatory bodies and are not
responsible to them. . "
4. Most national committee structures mirror the ISO international committee structure.
5. The most active countries participate at all levels including the working group level, where
standards are negotiated and drafted. Less active countries tend to participate only at the
technical committee and subcommittee levels.
6 Heads of delegation are most often selected or elected by members of national standards
bodies or members of national technical committees, but there are a surprising number who
are appointed. .
7. A significant number of heads of delegation work for standards bodies,
8 While most countries participating in ISO/TC 207 declare that they'have membership
balance and participation in principle, in fact very few seem able to demonstrate .that they
have achieved such balance and participation.
9. After industry, government seems to have the second highest level of participation and
influence.
10. Government representatives most often act as stakeholders with an equal voice in
deliberations.. ' .
11. The roles that most government representatives can play in the standards process are not
limited.
12. Industry has the highest level of representation and influence.
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13. Industry is most comfortable with the standards development process. . . .
14. Industry is the most cohesive group (often across national delegations) because of the work
of associations and the role of transnational. ' .
'15. Small and-medium sized enterprises are under-represented in standards deliberations.
16. NGOs are under-represented on national committees and can be suspicious of the process.
17. NGOs have more significant representation as Liaison organizations. '
18. Other participants such as consultants and academics provide specific expertise. They do not
generally advocate the positions of a constituency.
19. The process for adopting international standards is similar to .the process for-approving
national standards. Consensus among stakeholders must be achieved for a standard to be
/approved. , , ' -
20, Some countries adopt international standards through an administrative procedure.
21. It is unlikely that ISO 14001 will be cited in legislation or regulation.
22. ISO 14001 is being actively recognized and piloted by regulators in ways other than formal
citation in regulation. , , '
23. Regulators in many countries are providing or are actively considering providing regulatory
relief to organizations registered to ISO 14001. .'
. 24. Regulatory relief means relief of the administrative burden, not relief from regulatory
requirements. , - . , . '
25.. Few countries have come to terms with how to use the ISO 14000 series for procurement.
26. The governments of many countries provide funds to support participation in the ISO
' development process, training and implementation, and'certification torISO 14001;
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