United States
Environmental Protection
Agency
Office Of Water
(4204)
EPA 832-R-96-002
December 1996
r/EPA
Environmental Management
System Demonstration Project
\
Final Report
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Environmental Management System
Demonstration Project
Final Report
December 1996
Written by:
Craig P. Diamond
Project Manager
NSF International
2100 Commonwealth Blvd.
Suite 100*;
Ann Arbor,. MI 48105
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CONTENTS
I. Foreword -.'. ................... ............., 1
Organization of the Report ... 1
Advice to Readers 2
Acknowledgments 2
n. Executive Summary 3
Project Overview 3
Project Findings .. .. 4
Conclusions .....',. 8
HI. Introduction and Project Overview ..;... . •.. 9
Project Summary .... . ; 9
Project Activities in Detail............................................. 12
Profile of Participating Organizations . ...:.... 13
, • - ' \ ' .'• ' , ' •
IV. EMS Implementation Progress ......... 16
„ Background on EMS Assessments and Data Analysis .: 16
Self-Assessment Results ^. '........^....... ^........ 17
Findings from Independent Assessments ............: 21.
V. Findings on Key EMS Implementation Issues 25
Incentives for Implementing an EMS 25
Benefits and Costs of Implementation 27
Barriers and Keys to Successful Implementation . .-. .31
Links with ISO 9000 and Health & Safety .. 33
Comparison of SMEs and Large Organizations .34
Recommended Guidance and Implementation Tools 36
Participant Feedback on ISO 14001 .... .38
Participant Advice to Regulators '. .42
VI. Conclusions 43
Major Lessons Learned 43
Remaining Questions and Areas for Future Study -..'.' 44
VII. Case Studies • ............: .46
- 3M Corporation '. .41
Allergan, Inc. ...............:..................... .:..... .51
Commodore Applied Technologies .-..;•......' 54
Fluke Corporation 56
Globe Metallurgical Inc. .: ....:. 59
Hach Company .,62
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KJ. Quinn & Co ...' 67
Lockheed'Martin Federal Systems 70
Madison Gas and Electric Company 73
Milan Screw Products '. .. 76
NEO Industries Ltd. .. 80
NIBCO Incorporated 83
Pacific Gas and Electric Company 86
Pitney Bowes Lie 89
TRINOVA Corporation 92
United States Postal Service 95
Washtenaw County Government : 98
Bibliography ....-.- 101
DC. Appendices , 102
Appendix A: Background on ISO 14000, EMS Standards, and Registration .102
Appendix B: Questions Asked of Participants at Conclusion of Project 107
Appendix C: Elements of the ISO 14001 Standard: A Snapshot.,.. 108
Appendix D: Excerpts from NSF's EMS Self-Assessment Tool 109
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I. FOREWORD
The ISO 14000 series of standards, in particular the ISO 14001 Standard for environmental
management systems (EMS), has become one of the most widely discussed developments in
environmental management in both the private and public sectors. The ISO 14001 Standard was
officially approved in September 1996, and is expected to become as pervasive in the
international marketplace as the ISO 9000 series of quality management standards. This
expectation has driven many organizations to devote significant resources into preparing for ISO
14001. Despite this level of investment, there is still a great deal of uncertainty about the
implementation of the ISO 14001 Standard. Although several organizations in Europe have
completely implemented a formal EMS based on standards (e.g., BS 7750, EMAS, IS 310),
relatively few organizations in the United States have done so. Therefore, in the U.S. there is a
need for "real life" examples from organizations about the challenges and benefits of
implementing an EMS and the incentives for doing so.
This final report on NSF International's EMS Demonstration Project conveys the experiences of
18 organizations as they attempted to implement the ISO 14001 Standard from March 1995
through June 1996. The project was funded through a cooperative agreement from the U.S.
Environmental Protection Agency (EPA), Office of Wastewater Management. The report will be
of interest to many types of organizations interested in EMS implementation, including:
manufacturers and other organizations considering whether to implement the Standard;
regulatory agencies; engineering and management consulting firms; law firms; training
organizations; banks; and insurance companies.
The Demonstration Project focused on EMS implementation issues, not on registration^ In this
report, "EMS implementation" refers to an organization's effort to develop an EMS based on the
ISO 14001 Standard; the term does not refer to maintaining and improving the system after it is
implemented. Participating organizations varied significantly in the extent to which they came
into the project with the elements of ISO 14001 akeady in place.
The organizations, which participated voluntarily* were not required or expected to become
registered to ISO 14001 during or after the project; nor were they required to implement all the
requirements of the Standard over the course of the project.
Organization of The Report
The Introduction and Project Overview outlines the activities of the project in some detail and
provides an overview of the 18 organizations that participated. The section on EMS
Implementation Progress provides an analysis of how the project participants as a group made
.progress on implementing the ISO 14001 Standard over the course of the project. The Findings
on Key EMS Implementation Issues discusses several EMS implementation issues, including.
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incentives, benefits, and keys to success. It also offers a list of suggested EMS implementation
guidance tools. A brief Conclusions section discusses major lessons learned from the project
and suggested areas for further inquiry. The Case Studies, which were written by the
participating organizations and edited by NSF, convey the EMS implementation experiences of
the participants from their own viewpoints (to maintain confidentiality, none of the other sections
of the report refer to specific organizations by name). Appendices A-D are provided to help
clarify certain parts of the project and this report. For those readers who are not familiar with the
ISO 14001 Standard, it may be helpful to refer to Appendix C which provides an overview of the
elements of ISO 14001.
Advice to Readers
This report assumes a basic knowledge of ISO 14000 and of the ISO 14001 EMS Standard. A
thorough understanding of environmental management systems is helpful, but not required. For
those who are not very familiar with the language of ISO 14001, it is suggested that the Standard
be referenced regularly while reading the report.
Acknowledgments
NSF International would like to thank the U.S. EPA, Office of Wastewater Management, for
providing the majority of the funding for the EMS Demonstration Project.
NSF also wishes to thank the 18 participating organizations (and the individuals who represented
them in the project) for their invaluable contributions through the case studies, self-assessments,
meeting presentations, and advice to NSF project staff (the organizations are listed in Section El
of the report). NSF would also like to gratefully acknowledge the following individuals who
have given much of their time to the planning and implementation of the EMS Demonstration
Project, and who have contributed to the project's success:
Thomas Ambrose, HS&E Management Advisor .
Henry Balikov, TLI Systems . . . >
Joe Egan, Tucker Alan, Inc. ,
Jimmy Margolis, Arthur D. Little, Inc.
Philip Stapleton, Glover-Stapleton Associates, Inc.
Wayne Tusa, Environmental Risk & Loss Control, Inc.
David Van Wie, Robert G. Gerber, Inc.
Finally, the author would like to thank Anita Cooney and Michael Mix of NSF International for
their assistance in the development of this report.
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Hi EXECUTIVE SUMMARY
Project Overview
This final report on NSF International's Environmental Management Systems (EMS)
Demonstration Project summarizes the EMS implementation experiences of 18 organizations of
a variety of types and sizes. The project, which used the ISO 14001 Standard as the model for an
EMS, was funded through a two-year grant from the U.S. Environmental Protection Agency,
Office of Wastewatef Management (October 1994 - September 1996). The EPA funded the
project because it recognized that both private organizations and regulatory agencies were in
need of practical information about the process of implementing the ISO 14001 Standard.
Participating organizations included 16 private companies, one government agency, and one
government-owned corporation (the U.S. Postal Service). The companies ranged from small
manufacturers with fewer than 100 employees to multinational corporations.
The goals of the project were to: (1) document the experiences of a variety of organizations as
they attempted to develop an EMS based on ISO 14001; (2) demonstrate the benefits and
challenges of, and incentives for, EMS implementation; (3) determine what types of tools and
assistance organizations need to be successful with EMS implementation; and (4) provide, a
forum for organizations to learn from each others' EMS experiences. Another important
objective of the project was to identify and assess any differences that might exist between small
and large organizations in their ability to implement an EMS. •
After organizations were recruited for the project, an initial training session was held in March
1995 to familiarize participants with ISO 14000 and EMS. Following the training, participants
conducted self-assessments of their EMS against the requirements in ISO 14001 using a self-
assessment tool developed by NSF International. Three additional meetings were held (in
August and December 1995, and June 1996) during which participants shared lessons learned
from their EMS implementation experiences. Final EMS self-assessments were conducted prior
to the last meeting in June 1996. In August 1996, participants submitted responses to specific .
questions as well as .self-written EMS implementation case studies (the case studies are included
in the report). In October 1996, EMS auditors conducted independent EMS assessments for four
of the participants to determine if significant differences might exist between the results of the
self-assessments and independent assessments.
To meet the objectives of the project, NSF collected and analyzed information from four sources:
(1) results of the initial and final EMS self-assessments, and of the four independent assessments;
(2) responses to the specific questions about EMS implementation; (3) the self-written case
studies; and (4) observations made at the four project meetings.
'3 •'•
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Project Findings
EMS Implementation Progress
The results of the EMS self-assessments showed that, overall, participants made notable progress
on implementing the ISO 14001 Standard over the course of the project (the average period of
time between the initial and final self-assessments was approximately 11 months). Whereas the
initial self-assessments showed that the group as a whole had only 22% of the requirements of
the Standard complete, the final self-assessments showed that the group had 50% of the
requirements complete. .
Important Note: For both the initial and final self-assessments, participants evaluated themselves
on 63 requirements which comprise all 17 elements of ISO 14001. Each requirement could be
evaluated on five different levels: No Acdon (NA), Initiation (IN), Partial Implementation (PAR),
Complete Implementation (COM), and Evaluated & Sustained (ES). NA, IN and PAR are
considered incomplete, while COM and ES are considered complete (in the self-assessment tool,
incomplete was denoted by "NO," while complete was denoted by "YES").
As a whole, participants also made progress on each of the 17 elements of ISO 14001, although
more progress was made on some elements than on others. The element of ISO 14001 with the
highest level of implementation was Policy, while EMS audit was least implemented (84% of
the requirements under Policy, and 24% under EMS audit, were evaluated as complete at the
conclusion of the project). ,
The results of the independent assessments showed that there were significant differences in how
the organizations and independent auditors evaluated the requirements of ISO 14001.
Approximately 30% of the requirements evaluated in the four organizations were evaluated
differently by the organization and the independent auditor on the YES/NO response. Twenty-
four percent were rated lower by the independent auditors; i.e., the independent auditor evaluated
these requirements as NO, but the organization evaluated them as YES. Six percent were rated
higher, i.e., the independent auditor evaluated these requirements as YES, but the organization
evaluated them as NO.
Since 24% of all the requirements were evaluated lower by the independent assessors, and only
6% were evaluated higher, these findings suggest that the % YES of the initial and final self-
assessment results would have been lower if all the EMS assessments had been conducted by,
independent auditors father than by the organizations-themselves.
The independent auditors made some additional observations during the audits. Most notably, in
the three organizations with ISO 9000 systems, the quality management staff was surprisingly
disconnected from the environmental management staff. It appeared that the organizations were
not taking full advantage of their existing ISO 9000 systems to develop EMS procedures and
documentation. ,
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Incentives for Implementing an EMS ,
Participants were asked at the end of the project to list their organizations' incentives for
implementing ISO 14001. The incentives most commonly cited by participants; are listed below.
The number of participants that cited each incentive is provided in parentheses (note: fourteen
participants listed their incentives, and some cited more than one incentive):
• , Competitive advantage (7); ,
• Improved.environmental performance (6);
Possible ISO 14001 registration (5);
• Enhanced regulatory compliance (4); and
• Possible regulatory flexibility (3).
Competitive advantage was also mentioned quite frequently at meetings, although participants
did not always specify whether the advantage would be derived from external recognition (i.e.,
through registration) or from the benefits Of improved environmental management.
Benefits of EMS Implementation . ,
Several benefits of implementing an EMS were realized by participants over the course of the
project. In addition, those organizations which had extensive EMSs at the beginning of the
project reported benefits they had realized before becoming involved in the project. The number
of participants that cited each benefit is provided in parentheses (note: fourteen participants listed
benefits, and some listed more than one). Reported benefits include:
• Improved cooperation and environmental awareness among employees (5);
• Improved procedures and documentation (5);
• Enhanced regulatory compliance (3); and ,
• Improved environmental performance (5).
Participants had not realized reduced environmental management costs or access to international
markets by the conclusion of the project. Although these benefits are often mentioned in
conjunction with ISO 14001, it will likely take more time for organizations to realize these
benefits. .
Keys to Successful Implementation , ,
The'following keys to successful EMS implementation emerged as common themes during the
group meetings and in participants' responses to questions at the conclusion of the project.
These include:
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Secure top management commitment early in the process;
Gain a thorough understanding of the ISO 14001 Standard;
Perform a thorough self-assessment;
Involve many functions and staff levels in the planning process;
Initially, set a small number of achievable environmental objectives; and
Build on existing business practices.
Links with ISO 9000 and Health & Safety
A majority of project participants have facilities that are either registered to ISO 9000 (ISO 9001
or 9002) or working towards registration (only two organizations reported that they were not
registered or pursuing registration). Most of the organizations with ISO 9000 experience
indicated that they would model several elements of the EMS after their quality system, or that
they would at least partially integrate certain elements of ISO 9000 and ISO 14001. However,
only a few participants reported at the end of the project that they intended to fully integrate the
two systems hi the near future. This finding is consistent with observations made during the
independent assessments. .
Six participants reported they were intending to integrate ISO 14001 with their health-& safety
program.
Comparison of SMEs and Large Organizations
In the Demonstration Project, small and mediums-sized enterprises (SMEs) were defined as
having fewer than 1,000 employees organization-wide. Based on question responses from both
SMEs and large organizations in the project, some differences between the two types of
organizations were observed.
Incentive's. For certain incentives identified by participants (i.e., competitive advantage,
regulatory relief) there was not a clear difference between the proportion of SMEs and
large organizations citing them as incentives. However, for other incentives there were
notable differences. SMEs were more likely than large organizations to identify enhanced
compliance and improved documentation as motivating factors. Large organizations, on
the other hand, were more likely to identify improved environmental performance and
pollution prevention as motivating factors.
Barriers. SMEs and large organizations cited most EMS implementation barriers (e.g.,
promoting the EMS concept within the organization, achieving thorough documentation)
in roughly equal proportions. However, a much greater proportion of SMEs cited lack of
time and resources as a barrier.
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Recommended Guidance and Implementation Tools
Based oh the experience of the organizations in .the project, it became evident that certain types
of guidance are very important for organizations of all types and sizes attempting to implement
ISO 14001. These include:
• Clarification of the intent of ISO 14001;
• A checklist or other tool to conduct an EMS self-assessment;
• Guidance on how to identify and assess the significance of environmental aspects and
impacts;
• A step-by-step implementation guide;
• Examples of EMS manuals, policies, and procedures; and
• EMS implementation case studies.
Feedback on the ISO 14001 Standard, and Advice to Regulators !
Participants reported on their general and specific concerns about the ISO 14001 Standard. In
general, the participants believed that the Standard was a good model for an EMS. However,
most participants expressed at least one overriding concern about the Standard, and some specific
comments (specific comments are presented in section V of the report). The greatest overriding
concern was the potential for certain requirements to be variably interpreted by different auditors.
Other commonly reported concerns included confusion over the definition of "environmental •
aspects;" an overemphasis on documentation; and confusion about whether written procedures
were necessary for particular requirements.
Participants also offered comments to the regulatory community about how government agencies
should integrate ISO 14001 into their regulatory approaches. Most participants stated that
regulators should offer incentives — primarily "regulatory flexibility" — to companies that
implement an EMS. These proposed incentives included: • , ,
• Reductions in reporting; .
• Reductions in site inspections and audits;
• Reductions in fines; . .'-•'.•,
• Elimination of penalties and NOVs for various environmental compliance issues; and
• Fast-track permitting.
Many participants expressed a concern about the voluntary disclosure of self-audits (ISO 14001
requires organizations to conduct, and maintain the records of, EMS audits). Several participants
also commented that a greater level of trust was needed between regulators and the regulated
community. -
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Conclusions
Implementing ISO 14001 is Feasible in a Wide Variety of Organizations
The experience of the Demonstration Project suggests that an EMS based on ISO 14001 can be
implemented in a wide variety of organizations, but varying amounts of guidance and assistance
are required for different organizations. The main factors that seem to determine an
organization's ability to implement an EMS are (1) its experience with EMS, ISO 9000, or other
management system concepts; (2) the level of commitment from its top management; and (3) the
resources available to the organization to develop the necessary procedures and documentation.
Since SMEs are more likely to lack adequate resources, they will probably require more guidance
and take longer to complete EMS implementation than large organizations. /
EMS Implementation Can Bring Concrete Internal Benefits
Project participants reported many benefits from EMS implementation that were not market or
trade related, including enhanced environmental awareness, improved documentation, and
pollution prevention. These benefits were realized within the one year time frame of the project,
and before any of the organizations had attained full implementation or registration.
Independent Assessments Can Provide an Important Check on Self-Assessments
The results of the independent EMS assessments suggest that organizations might have the
tendency to evaluate their systems higher than would independent auditors. The results may also
have important implications for the concept of "self-declaration," in which an organization
would declare itselfto be hi conformance with the ISO 14001 Standard rather than receive an
independent audit from a registrar. »
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. INTRODUCTION AND PROJECT OVERVIEW
In October 1994, the U.S. EPA, Office of Wastewater Management, awarded funding to NSF
International to manage the EMS Demonstration Project. EPA awarded the grant because it
recognized that both private organizations and regulatory agencies needed practical information
about the EMS implementation process in organizations of various types and sizes. NSF was
selected to manage the project because it had developed an interim EMS standard (NSF 110)
very similar to ISO 14001, and because NSF was an active participant in the ISO 14000
development process. .-...'
The goals of the project were to: (1) document the experiences of a variety of organizations as
they attempted to develop an EMS based on ISO 14001; (2) demonstrate the benefits and
challenges of, and the incentives for, EMS implementation; (3) determine what types of tools and
assistance organizations need to be successful with EMS implementation; and (4) provide a
._.'•" forum for organizations to learn from each others' EMS experiences. An important objective of
the project was to identify and assess any differences that might exist between small and large
organizations in their ability to implement an EMS (for the remainder of this report, smaller -
organizations will be referred to as small and medium-sized enterprises, or SMEs). In part, this
objective was intended to address concerns which arose during the Standard development
process regarding the applicability 6f ISO 14001 to SMEs.
The intent of the project was to examine the process of implementing an EMS based on ISO
14001. It was not within the scope of the project to measure or assess the effects of EMS
implementation on environmental compliance or other aspects of environmental performance. It
was also not required or expected that participating organizations would become registered to
ISO 14001 during or after the project. It is important to note that thisteport attempts to focus on
the experience of implementing an ISO 14001 EMS, as opposed to the benefits of already haying
one in place. However, those participants which came into the project with most ISO 14001
elements in place reported on the experience of having an established EMS as well as on the
experience of implementing certain requirements. Nevertheless, most of the feedback received
from the participants addressed then1 experiences with the process of implementing the EMS.
Project Summary ;
Project participants were recruited in late 1994 and early 1995. A project announcement and
interest form were sent to approximately 1,000 organizations. A few organizations were also
recruited individually. A maximum of 20 organizations were sought, and 18 were recruited
(there was no competitive selection process; i.e., all 18 organizations that expressed interest were
selected for the project). There was no fee charged for participation.
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The project consisted of two major activities: (1) EMS self-assessment and implementation; and
(2) group training and discussion. Each participant performed an initial assessment of its EMS in
the spring of 1995 using NSF's EMS Self-Assessment Tool. The participants used the results of
their initial assessments to develop EMS implementation action plans. Based on their action
plans, participants implemented the ISO 14001 Standard at their own pace. Each participant
conducted a second self-assessment in the spring of 1996 to determine progress made over the
course of the project. Following the final self-assessments, four participants received
independent EMS assessments conducted by EMS auditors. The results of these assessments
were compared to the final EMS self-assessments for the four participants. The purpose of the
independent assessments was to determine if organizations might evaluate their own systems
differently than independent auditors would.
In addition to self-assessment and implementation, the organizations convened in four meetings
. at NSF to receive training on EMS implementation and to discuss practical implementation
strategies. Based on feedback received from participants, these meetings were a very
constructive way to exchange ideas about EMS concepts.
At the conclusion of the project, participants submitted responses to a series of questions
regarding their EMS implementation experiences; these responses are summarized in Section V,
Findings on Key EMS Implementation Issues (the questions are listed in Appendix B).
Participants also prepared self-written case studies which are included in Section VH (Note: 14
of the 18 organizations submitted question responses regarding their EMS implementation
experiences; 17 submitted case studies).
Figure I'provides an overview of the project.
10
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Project Activities in Detail
EMS Self-Assessments and Implementation
Each participant performed two EMS self-assessments, one in the spring of 1995 (following the
first meeting) and one in the spring of 1996 (before the last meeting).
The results of the self-assessments were aggregated and summarized to serve two purposes: (1)
to provide an internal benchmark for the group; and (2) to measure group progress over the
period of the project.
Self-assessments were conducted internally by the organizations (some had consultants assist
with the self-assessment, others did not) using NSF's EMS Self-Assessment Tool. The tool was
developed prior to the first meeting under the direction of an ad hoc advisory group. The group
was comprised of environmental management consultants, in addition to environmental
managers from some of the companies recruited to the project. The tool contains a checklist mat
allows the user to assess how the organization's EMS compares to the requirements in ISO
14001. The self-assessment results and a brief description of the EMS Self-Assessment Tool are
provided in Section IV.
Following the initial self-assessments in the spring of 1995, each participant identified those
EMS elements it wanted to develop '(please refer to Section IV for an explanation of the self-
assessment process). While some of the organizations already had several elements of ISO
14001 already in place, others needed to make more substantial changes to their existing
environmental management practices to develop an ISO 14001 EMS. As mentioned previously,
participants were not required to implement any particular requirements of the Standard in any
specific time frame. Rather, they were asked to make the best effort possible, based on their own
priorities, over the course of the project.
Group Training and Discussion
Group meetings were held at NSF International in March, August and December of 1995, and in
June of 1996. The purpose of these meetings was to provide EMS training and to create a forum
in which participants could learn from each other. Each organization was represented at the
meetings by one to three individuals. The attendees served a variety of roles in their
organizations including company presidents, environmental managers, and quality managers.
The first three meetings were two-day sessions, while the last meeting was a one-day session.
The first meeting provided training on the requirements of ISO 14001 and included an overview
of basic EMS concepts. NSF's EMS Self-Assessment Tool was provided to each participant at
the meeting so that each organization could conduct a self-assessment of its EMS before the
12
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second meeting. At the conclusion of the first meeting, participants were asked to make their
best effort to implement the requirements of ISO 14001 over the course of the project, and were
encouraged to do so at a pace appropriate to their individual situations.
The second meeting provided further training on specific topics related to EMS implementation,
including: identifying environmental aspects and impacts; setting environmental objectives and
targets; promoting the EMS concept within an organization; and integrating ISO 14001 with ISO
9000. In addition, each participant reported back to the group on its experience with the EMS
self-assessment and on progress it had made in implementing the requirements in the Standard.
Individual progress reports (each about 10-15 minutes) were followed by questions from the
group and discussion. For both the training and report-back sessions, participants were broken
into smaller groups to facilitate1 discussion.
' f ~ ' '.'-.' %
The third meeting was similar to the second, but more time was devoted tp feedback and
discussion than to training. Each participant presented .its progress on EMS implementation, and
discussed keys and barriers to success. Following the progress reports, plenary workshops were
held on estimating the costs and benefits of EMS implementation, and on evaluating
environmental performance. In addition, guest speakers updated the group on developments in
EMS registration and accreditation. In the,fourth meeting, the majority of the agenda was
devoted to sharing keys and barriers to EMS implementation; and lessons learned over the course
of the project.
Profile of Participating Organizations _
Ten of the 18 participating organizations are large, and eight are SMEs (for the purpose of
categorization, large organizations were defined as having over 1,000 employees organization-
wide, while SMEs were defined as having fewer than 1,000 employees organization-wide)! The
organizations provide a variety of products and services, and range from Fortune 100
corporations to small manufacturers.. At the outsetof the project, the organizations also varied
significantly in their approach to environmental management. In particular, they varied in the
extent to which procedures were formalized and documented, and in the extent to .which
activities that go beyond regulations had been integrated into their existing environmental
management practices. , , ,
A majority of the participants are either registered to ISO 9000 or working towards registration.
Approximately one-half operate facilities overseas. Table I lists the 18 organizations that
participated in the project. They consist of 16 private companies, 1 government agency, and one,
government-owned corporation (the U.S. Postal Service). It is important to note that the
organizations in the project, because they participated voluntarily, were likely inclined to make
more progress on EMS implementation than would an average cross section of companies, in the
U.S.; most of the participants had already decided to pursue EMS implementation before
becoming involved in the project.
• • . , • ''•'.;'- \ • • .'•.',
' . . . "-'' is ''•'. t '.'-;••
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As of December 1996, two organizations (both companies) in the project had facilities that were
registered to ISO 14001 or other EMS standards. Many others are planning to become ISO
14001 registered within the next few years. Others may not be specifically planning for
registration, but are committed to developing an EMS based on the requirements of ISO 14001.
14
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Table I: Brief Profiles of Participating Organizations
Organization
3M Corporation
Allergan, Inc.
Commodore Applied
Technologies
Fluke Corporation
Globe Metallurgical
Hach Company
KJ. Quinn & Co.
Lockheed Martin
Federal Systems
Madison Gas &
Electric Company .,
Milan Screw Products
NEO .Industries Ltd.
NIBCOInc.
Pacific Gas & Electric
Pitney Bowes Inc.
Prime Tanning Co.
TRINOVA Corporation
U.S. Postal Service
Washtenaw County
Government
Headquarters
St. Paul, MN
Irvine, CA
Columbus, OH
Everett, WA
Selma, AL
Ames, IA ,
Seabrook, NH
Manassas, VA
Madison, WI •
Milan, MI
Portage, IN
Elkhart,IN
San Francisco, CA
Stamford, CT
Berwick, ME
Maumee, OH
Washington, DC
Ann Arbor, Ml
Products/Services*
Produces multiple products for the
industrial, commercial, consumer,
and health care markets
Produces Pharmaceuticals
Performs remediation technology
R&B • -; " . ••_..
Produces electronic test and
measurement instruments
Produces silicon metal and
ferroalloys ,
Produces instruments for water
analysis , .
Produces coatings and adhesives
Produces semiconductors and
computer systems
Provides electricity and natural gas
Produces screw machine products
Performs metal finishing
Produces fluid handling products
Provides electricity and natural gas
Produces mailing systems and other
office machines
Produces finished leather
Produces engineered components
and systems for industry
Provides mail delivery services
Provides a variety of municipal
services ••-.'. .-'-'.
Size"
Large
Large
Small
Large .
Med
Med
Small
Large
Med
Small
Small
Large
Large
Large
Med
Large
Large
Large
Note: Please refer to the Case Studies for a more detailed description of products/services.
Note: Small denotes fewer than 250 employees; Med denotes 250-1000 employees; Large denotes over
1000 employees (applies to entire organization). ,
15
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IV. EMS IMPLEMENTATION PROGRESS
-.'.-• , • • f i
Background on EMS Assessments and Data Analysis
• • • .. . \ . • •• . .'' ' r •• ' -'•'''
Self-Assessments
Progress on EMS implementation over the course of the project was measured by comparing the
results of the initial and final self-assessments conducted using NSF's EMS Self-Assessment
Tool. The initial self-assessments were conducted between April and July 1995, while the final
self-assessments were conducted between March and May 1996 (thus, the average time between
self-assessments was approximately 11 months). The analysis provided in this section reflects
results for the entire group of organizations, not for individual participants. Of the 18
organizations in the project, 15 submitted data on both their 1995 and 1996 self-assessments;
therefore, 3 of the 18 organizations are not included in the aggregate data analysis.
The EMS Self-Assessment Tool contains a checklist which breaks the 17 elements of ISO 14001
Standard down into 63 separate requirements. The checklist does not interpret the Standard,
rather each requirement is taken verbatim from ISO 14001. The user evaluates each requirement
on five possible "implementation levels": No Action (NA), Initiation (IN), Partial ;
Implementation (PAR), Complete Implementation (COM), and Evaluated & Sustained (ES). If
. the requirement is evaluated as COM or ES, it is considered to be satisfied, or complete ("YES");
if the requirement is evaluated as NA, IN, or PAR, it is considered to be not satisfied, or not
complete ("NO"). The reader should refer to Appendix D which provides a sample page of the
assessment tool and detailed descriptions of each implementation level:
Because the final ISO 14001 Standard was published only recently (September 1996), the Self-
Assessment Tool was based on the Draft International Standard (DIS). This does not affect the
results of the project because there are no substantive differences between the DIS and .the final
version of the Standard. ,
.A note regarding the initial self-assessments. The initial self-assessments were conducted using
an assessment tool which contained the requirements of both the ISO 14001 draft and another
EMS standard (NSF 110), while the final self-assessments used a revised self-assessment tool
which contained only the requirements of the ISO 14001 draft. Participants were given the
option to complete the initial assessment using NSF 110, ISO 14001, or both. Three participants
did not complete the 14001 assessment; those organizations were asked to retroactively evaluate
themselves on how their EMS would have compared to ISO 14001 in the spring of 1995. (Note:
NSF 110 was developed by NSF International as an interim EMS standard in the U.S. The NSF
standard was used in the initial phases of the project because, at the time, NSF 110 was a .
completed standard and ISO 14001 was in an earlier draft stage; as the.project progressed and
interest in ISO 14001 increased, a decision was made to use ISO 14001 in the project rather than
NSF 1.10). . :• "'. '. •
'••'•'-.• . - •' .16 •-.'-..'' •' ''
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Independent Assessments
In October 1996, four project participants received EMS assessments conducted by independent
EMS auditors. The assessments were conducted by experienced environmental auditors utilizing
the same assessment tool used in the self-assessments. Each assessment took two days and was.
conducted by two auditors. Three of the assessments were conducted for single facilities, and
one was conducted for an entire organization. As discussed below, there were significant
differences between the results of the self-assessments and independent assessments for the four
organizations in which independent assessments were conducted.
Self-Assessment Results
The initial'and final self-assessment results were aggregated and analyzed to evaluate (1) overall
implementation progress on the Standard as whole; and (2) implementation progress on each of
the 17 elements of ISO 14001. As presented and discussed below, progress was made on the
Standard as a whole and on all of the 17 elements.
Overall Progress on ISO 14001
A total of 945 self-assessment responses were analyzed (15 organizations x 63 requirements in
assessment tool = 945 total responses). - In the initial self-assessment, 22% of responses were
"YES" (i.e., COM or ES) and 78% were "NO" (i.e., NA, IN, or PAR). However, in the final
self-assessment, 50% of responses were "YES" and 50% were "NO." In Table n, these results
are further broken down into the five implementation levels.
Table H: Overall Progress on ISO 14001 Implementation
Implementation
Level
No Action (NA)
Initiation (IN)
Partial Implementation {PAR)
Complete Implementation (COM)
Evaluated & Sustained (ES)
Initial
Results
25%
23%
30%
18%
4%
Final
Results
8%
15%
27%
37%
13%
Table It also shows that participants, as a group, did not begin ISO 14001 implementation "from
scratch," since only 25% of the requirements were evaluated as No Action initially.
17
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There was a large variation amongst project participants both on EMS implementation progress
and on the %YES of requirements for the initial and final self-assessments. Some participants
evaluated well under 50% of their requirements as YES, while others evaluated well over 50% of
their requirements as YES.
; Table in shows the %YES of individual participants for both, the initial and final s
assessments. Each column represents a participant (there are only 15 columns because 15 of the
1 8 project participants submitted both their initial and final self-assessments). The columns are
ordered, from left to right, by the %YES in the initial self-assessments. These data illustrate the
extent to which project participants varied in their levels of EMS implementation at both the
beginning and end of the project. Note that only three of 15 showed no progress over the course
of the project. The two negative results are likely due to the final self-assessments being more
rigorous than the initial self-assessments in those two organizations. ,
Table ffl
EMS Implementation Progress of Individual Participants
Initial
%YES
Final
%YES
Final-
Initial •
75
100
25
54
100 ,
46
'
,41
84
43
38
,
37
-1
33
•
33
o
27
18
4>
21
51
30
21
41
20
16
81
'
65
6':
41
35
0
62
62
0
52
52-
0
27
27
0
11
11
0
5 .
5
Progress on the Individual Elements of ISO 14001
Table IV shows how the elements ranked for both the initial and final self-assessments in terms
of the % of responses evaluated as "YES" within each element. The %YES was calculated by
dividing the total number of responses in an element into the number of responses evaluated as
"YES." For example, there are six requirements in the Self-Assessment Tool under Policy.
Since 15 participants responded, there was a total of 90 responses for Policy. -Seventy-six of the
90 responses (84.4%) were evaluated as "YES."
Table V shows the same information as Table IV, but in a different format. The 17.elements of
ISO 14001 are ranked by the extent to which project participants made implementation progress
on them over the course of the project. The difference between the initial and final self-
.assessment for each element is provided in the third column. For example, although 6.7% of
responses for Records were evaluated as "YES" (COM or ES) in the initial assessments, 48.3%,
or responses were evaluated as "YES" in the final assessments. ,
18
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Table IV
Ranking of ISO 14001 Elements - Initial and Final Self-Assessments
ISO 14001 Elements - Initial Rank
4.3.2 Legal and other requirements
4.2 Environmental policy
4.4.7 Emergency prep/resp
4.4.1 Structure and responsibility
4.5.1 Monitoring and measurement
4.3.3 Objectives and targets
4.4.3 Communication
4.4.6 Operational control
4.6 Management review
4.4.5 Document control
4.4.2 Training/awareness/competence
4.3.4 Environmental mgmt. program
4.3.1 Environmental aspects
4.5.2 Nonconf/corr&prev action
4.5.4 EMS audit
4.4.4 EMS documentation
4.5.3 Records
%YES
Initial
53.3
44.4
35.6
28.3
24.4
22.2
22.6
20.0
20.0
19.0
18.9
17.8
15.6
13.3
13.3
10.0
6.7
ISO 14001 Elements - Final Rank
4.2 , Environmental policy
4.3.2 Legal and other requirements
4.4.1 Structure and responsibility
4.3.3 Objectives and targets
4.3.4 Environmental mgmt. program
4.4.7 Emergency prep/resp
4.4.2 Training/awareness/competence
4.3.1 Environmental aspects
4.4.6 Operational control
4.5.3 Records
4.4.5 Document control
4.5.1 Monitoring and measurement
4.6 Management review
4.4.4 EMS documentation
4.4.3 Communication
4.5.2 Nonconf/corr&prev action
4.5.4 EMS audit
%YES
Final
84.4
66.7
61.7
57.8
57.8
57.8
56.7
48.9
48.3
48.3
43.8
40.0
37.8
36.7
35.6
31.1
24.0
19
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Table V
Implementation Progress on Individual ISO 14001 Elements
ISO 14001 Element
4.5.3 Records
4.2 Policy
4.3.4 Environmental mgmt program
4.4.2 Training/awareness/competence
4.3.3 Objectives and targets
4.4.1 Structure and responsibility
4.3.1 Environmental aspects
4.4.6 Operational control
4.4.4 EMS documentation
4.4.5 Document control
4;4.7 Emergency preparedness/resp
4.5.2 Nonconformance/corr&prev action
4.6 Management review
4.5.1 Monitoring and measurement
4.3.2 Legal and other requirements '
4.4.3 Communication
4.5.4 EMS audit
Initial
%YES
6.7
44.4
17.8
18.9
22.2
28.3
15.6
20.0 '
10.0
19.0 ..
35.6 '•-
13.3
20.0
24.4
53.3
22.2
13.3
Final
%YES
48.3
84.4 \ -
57.8 , -
56.7
57.8
61.7.
48.9
48.3
36.7.
43i8
57.8
31.1
37.8
40.0
66.7
35.6
24.0
Final minus
initial
41.6
40
40 .
37.8 '
35.6
33.4 •-.
33.3
28.3
26.7
24.8
22.2
17.8
17.8
15.6
13.4
13.4
10.7
It is difficult to draw hard conclusions from Tables IV and V because many factors may
contribute to why certain ISO 14001 elements were more developed than others at the beginning
of the project, or why organizations 'addressed certain elements of the Standard before others.
However, a few observations from Tables IV and V are provided below.
> -. • • • •. _
Policy was evaluated the-highest in implementation in the final assessment (84.4%) and the
second highest in the initial assessment (44.4%). Moreover, Policy was ranked 2nd in progress.
EMS audit, on the other hand, was evaluated quite low in both the initial assessments (13.3%)
and final assessments (24.0%). It is perhaps not surprising that Policy was ranked high.
However, it is unclear why EMS audit was ranked so low. One possible reason is that
20
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organizations may choose to wait until most other EMS elements are in place before developing
an EJViS audit program. Another possible reason is that organizations may tend to rate
themselves down on this element because they have not yet performed an audit, even if they have
the procedures in place.
Although Records was evaluated the lowest in the initial assessments (6.7%), the greatest
progress was made on that element (up to 48.3%). On the other hand, Legal and other
requirements, which received the highest evaluation initially (53.3%), made relatively little
progress over the course of the project (up to 66.7%). It is not clear what factors may have
contributed to these results.
i
Environmental aspects was ranked quite low in the initial assessment (15.6%), but significant
progress was made over the course of the project (up to 48.9%). The low initial evaluation for
this element likely reflects that most organizations have not yet attempted to conduct a formal
assessment of their environmental aspects and impacts because doing so is not required under
traditional command and control. The significant progress made over the course of the project is
probably due to the fact that many participants recognized the importance of identifying
environmental aspects and impacts early on in the EMS implementation process.
Findings from Independent Assessments .
This section discusses the results of the four independent EMS assessments performed in
October 1996. First, the aggregate findings are analyzed. Then, several examples are given of
specific-requirements w.here. there were differences between the self-assessments and
independent assessments. Finally, some additional observations from the independent
assessments are discussed.
Aggregate Results
For the four organizations receiving independent assessments, a total of 252 requirements were
evaluated (4 x 63 requirements in assessment tool = 252). The evaluations were analyzed by
identifying all those requirements for which there were differences on the YES/NO response
between the self-assessment and independent assessment. The analysis showed that
approximately 76 of the 252 requirements, or 30%, were evaluated differently on the YES/NO
response. Twenty-four percent (61 out of 252) were rated lower by 'the independent auditors; i.e.,
the independent auditor evaluated these requirements as NO, but the organization evaluated them
as YES. Six percent (15 out of 252) were rated higher; i.e., the independent auditor evaluated
these requirements as YES, but the organization evaluated them as NO. Notably, 13 of the 15
requirements evaluated higher were in one organization.
These differences were distributed throughout the Standard. All of the 17 elements of ISO 14001
t
1 . • • 21
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showed at least one of the four organizations with a difference on the YES/NO response.
Moreover, 51 of the 63 requirements, showed at least one organization with a difference on the
YES/NO response; however, for only three of the 63 requirements did three or more of the four
organizations have differences on the YES/NO response. (
The most notable differences in the Standard between the self-assessments and independent
assessments were found in the sections on Objectives and targets and Environmental
management program. In Objectives and targets, five put of the 12 responses were evaluated
lower, while two were evaluated higher. The most significant differences were found in the
language requiring organizations to consider their significant environmental aspects and the
views of interested parties when setting environmental objectives. In Environmental
management program, seven put of 12 responses were evaluated down, while none were
evaluated up. The most significant differences in this section were found in the language
requiring organizations to include the means and time-frame by which objectives and targets will
be achieved.
i , • * ' • '
Since 24% of all the requirements were evaluated lower, and only 6% were evaluated higher,
these findings suggest that the %YES of the initial and final self-assessment results would have
been lower if all the EMS assessments had been conducted by independent auditors rather than
by the organizations themselves. And because seven out of 12 responses in the Environmental
management program section of the Standard were evaluated lower, this section in particular
may have been evaluated too high in the self-assessments. These findings do not imply,
however, that less overall progress was made over, the course of the project, since any "seif-
assessment bias" would have been a factor in both the initial and final self-assessments. In fact,
there was likely more bias in the initial self-assessments because the organizations'
understanding of the Standard was probably not as thorough. This suggests that the overall
progress may have actually been greater than the observed difference, even though the initial and
final % YES may have been lower than reported in the self-assessments.
Specific Examples from the Standard
Two types of differences were observed between the self-assessments and independent
assessments:
• . differences in how the organization and the auditors interpreted the intent of ISO 14001
requirements; and
• differences in opinion on what environmental management practices satisfied particular
ISO 14001 requirements. (Note: this could be the case even if there is agreement between
the organization and the auditors on the intent of the Standard).
-------
A small number of differences found between the self-assessments and independent assessments
were due to auditor oversights.
Most of the differences appeared to fall under the second type - differences in opinion ~ but in
many cases it was difficult to differentiate between interpretation and opinion since the two are
so closely linked. However, in some cases the differences could be explained fairly clearly by
one type or the other. A few examples of each case are provided below.
Differences in Interpretation. One organization's Environmental policy did not have the
terms "prevention of pollution" or "pollution prevention;" rather, it had the terms "waste
management" and "waste minimization." While the independent auditors felt that the
word "prevention" was required, the organization believed that "minimization" was
sufficient. Therefore, the organization evaluated itself as COM on this requirement,
while the auditors evaluated it as PAR on the requirement.
Another organization was evaluated higher on several requirements due to a different
interpretation of the Standard. The reason for the auditors evaluating these requirements
higher than the organization did was the same in each case. The organization believed
that several requirements could not be complete (i.e., COM or ES) because they had not
implemented every element of the ISO 14001 Standard. For example, in Structure and
responsibility, the. organization evaluated itself as PAR on the requirement that
management provide "essential resources;" it did so because it did not have a specific
budget item for an ISO 14001 EMS. The auditors, however, evaluated this requirement
as COM because they had observed that the existing EMS was being adequately
resourced. . ,
Also in Structure and responsibility, the organization evaluated itself as NA (No Action)
on the requirement that the management representative report EMS performance to top
management. It reasoned that it could not report on the EMS because it did not yet have
an ISO 14001 EMS. Again the auditors evaluated this requirement as COM because the
management representative was hi fact reporting regularly to top management on the
performance of the existing EMS. The same type of situation occurred in the sections on
Training, awareness and competence and Management review in which the organization
evaluated itself as NO on certain requirements, while the; auditors evaluated the
organization as YES on those requirements.
Differences in Opinion. Under Objectives and targets, one organization was evaluated
lower on the requirement that significant environmental aspects be considered in
establishing and reviewing objectives and targets. In the judgement of the auditors, the
objectives and targets did not adequately address the organization's significant
environmental aspects. Unlike with the above examples, this YES/NO difference was not
23
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' - I •
caused, by differing interpretations of the Standard; both the organization and the auditor
agreed that significant aspects were .considered, but the auditors felt that aspects had not
been considered adequately. Li the same organization under Document control, the
auditors evaluated lower the requirement that "documentation shall be legible, dated, and
readily identifiable..." because the organization had not placed footers on each page of
controlled documents to prevent copying pages out of context. This reflects a difference
in judgement about what constitutes an effective document control system, rather than a
difference in interpretation of the requirement. > .
Iii another organization, under Training, awareness and competence, the auditors
evaluated lower the requirement that "training needs be identified" because the
organization had not indicated who would be responsible for identifying those needs.
Again, this difference is more a matter of judgement or opinion than interpretation, since
it does not state in the Standard that the organization must specify the individual who is
responsible for identifying training needs.
Additional Observations
Following the independent assessments, the audit teams were asked to report any additional
observations regarding the four organizations' EMS implementation processes. They observed
two areas, with which the organizations appeared to be most challenged: (1) EMS planning; and
(2) taking advantage of the existing ISO 9000 system to help develop EMS procedures and
documentation.
The auditors found that, as a whole, the four organizations were having more difficulty with
EMS planning (with the exception of Legal and other requirements) than with the other parts of
the Standard. Although all the organizations Had at least some of the planning requirements in
place, each organization needed to make improvements in several areas. For example^ one
organization had not considered all of its activities, products or services in identifying its
environmental aspects. Another organization had set objectives and targets, but had not
communicated them to upper management. A third organization had identified significant
environmental aspects and set objectives and targets, but had not adequately identified the means
and time-frame for achieving the objectives and targets. ,
The auditors also found that those organizations with ISO 9000 systems (three of the four
organizations were registered to ISO 9000) were not taking full advantage of their internal
expertise in management systems to prepare procedures and documentation for the EMS. In all
three cases, the environmental manager responsible for the EMS was surprisingly disconnected
from the activities of the ISO 9000 staff. For example, in one organization the environmental
manager was not aware that certain environmental procedures had already been incorporated into
the ISO 9000 system. : ' ,' '
24
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V. FINDINGS ON KEY EMS IMPLEMENTATION ISSUES
The primary source of information for this section is the set of question responses submitted by.
14 participants at the conclusion of the project. The questions (which are listed in Appendix B)
were open-ended; i.e., information was not collected through a formal survey that provided
response choices. This section also draws, to a limited extent, on information presented in the
self-written case studies and on observations made by project staff during the four'meetings held
at NSF International.
Incentives for Implementing an EMS
*.---'•"*' * . '. ' ' ^
There are many reasons why project participants decided to develop an EMS based on ISO
14001. The major incentives cited by participants are discussed below (note that incentives
should be differentiated from benefits, which.is discussed later in this section).
Competitive Advantage ,
1 • • - . • • ' •••' ' . *
Most participants believed that implementing an EMS will be important in maintaining or
gaining competitive advantage (seven of the organizations reported that competitive advantage
was an incentive for implementing an EMS, and competitive advantage was discussed frequently
at the meetings). However, participants did not always specify whether the advantage would be
derived from external recognition (i-e., registration) or from the benefits of improved
environmental management. For some participants, the anticipated competitive advantage may
have been different among departments in the organization. For example, two participants
reported that the environmental management department believed ,that competitive advantage
would be derived from improved environmental management, while upper management believed
that competitive advantage would derive from external recognition.
Although competitive advantage can be viewed as an obvious incentive (i.e., an organization
would not implement an EMS if it believed that doing so would not in some way lead to
competitive advantage), it is discussed here because it was mentioned quite frequently
throughout the project. • -.
Improved Environmental Performance
Six of the participants cited improved environmental performance as a reason for implementing
the ISO 14001 Standard. These organizations view the EMS as a good way to identify pollution
prevention opportunities and encourage continual improvement of environmental performance.
As discussed below under Benefits and Costs, several participants did realize improvements in
25
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environmental performance as a result of implementing an EMS.
Possible ISO 14001 Registration
Preparing for possible ISO 14001 registration was cited by five of the project participants as an
incentive for implementing an EMS. Anticipating the need for ISO 14001 registration is
important for companies that sell products internationally or operate facilities overseas. It is
believed by many that ISO 14001 registration could become a de facto requirement in
international markets and in the U.S. marketplace as well. Registration is also seen by some
companies as a potential way to demonstrate environmental performance to customers and other
stakeholders including regulators, insurance companies, and community groups.
Two participants stated that implementing ISO 14001 would be an effective way to demonstrate
good environmental practices externally, even though they did not tie that potential benefit
directly to registration.
Enhanced Regulatory Compliance
Four participants cited enhanced regulatory compliance as an important reason they were
implementing an EMS. Some participants viewed an EMS .as a mechanism for cost-effectively
maintaining compliance. Twice as many participants (eight) reported at the end of the project
that they believed implementing an EMS would in fact improve their compliance management.
It should be noted that the participants generally had very good systems to manage compliance
before the project began. . .
Possible Regulatory Flexibility
The term "regulatory flexibility" is used to describe regulatory changes such as fewer
inspections, reduced fines, and expedited permitting. Many organizations are hoping that having
both a solid compliance record and a proactive EMS will result in regulators focusing efforts on
organizations with significant compliance problems. Currently, regulatory flexibility appears to
be a fairly weak incentive (although three project participants did cite it as an incentive) because
regulatory agencies have not yet determined how to integrate ISO 14001 into their regulatory
programs. If regulators determine that regulatory flexibility can be effectively linked to ISO
14001, and if agencies begin to make significant changes, then regulatory flexibility may become
a much stronger incentive than it is now. - ,
26
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Benefits and Costs of Implementation
Every organization faced with the decision of whether or not to implement ISO 14001 must
estimate the potential benefits and costs. However, accurately predicting the actual benefits and
costs can be quite difficult. An organization may rely, on its previous experience with ISO 9000
or other management systems to estimate EMS benefits and costs, or it may look at the
experiences of other organizations.
A common question asked about ISO 14001 is, "What are the benefits and costs of implementing
the Standard?" This question is difficult to answer in general terms, because each organization
will realize different benefits and costs based on a variety of factors. These factors include the
Size of an organization, and the environmental impacts of its activities, products, and services.
An equally important factor is the extent to which an organization already has the elements of
ISO 1400i in place. It is likely that an organization with the majority of ISO 14001 elements
already in place before starting implementation will realize fewer benefits and incur fewer costs
than a similar organization which had significantly fewer elements already in place. An
organization's accounting methods can also affect the manner in which benefits and costs of
EMS implementation are calculated.
Benefits of Implementation
Measuring the benefits of EMS implementation can be challenging. Even for those benefits that
are seemingly measurable (e.g., environmental management cost-savings), it can be difficult for
an organization to 'conclude that the EMS alone is responsible for a given outcome given all the
other changes occurring in the organization. For example, one organization in the project said
that it had identified some specific environmental management cost-sayings while implementing
the EMS, but the organization could not pinpoint to what extent EMS implementation was ,
responsible for the improvement. •
At the conclusion of the project, organizations began to realize some benefits of their efforts.
Most of these benefits were recognized between the third and fourth meetings (i.e., between
December 1995 and June 1996), al>out one year after the beginning of the project. A few
participants realized some benefits that they had not anticipated at the beginning of the process.
Below is a discussion of the types of benefits participants reported they had realized (or not
realized) at the conclusion of the project. It is important to keep in mind that although most of
these benefits were realized over the course of the project during the ISO 14001 implementation
process, a few participants which already had well developed EMSs reported benefits they had
realized before they became involved in the project. It appears likely that many of the
organizations will realize further benefits over future business cycles.
27
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Improved Cooperation and Environmental Awareness Among Employees
Five participants reported that the EMS had enhanced awareness of environmental issues among
its employees. Enhanced awareness had resulted in improved employee morale, in addition to
improved operations. One organization said, "people want to do the right thing in the correct
manner but need to be made aware of the opportunities and methods available." The
organization noted that the EMS had provided employees with the "opportunities and methods"
to do the right thing. Another organization reported "an enhanced spirit of cooperation at the
facility" which was attributable to the EMS. This organization commented that "perceptions that
the work force doesn't care about management, or management doesn't care about the work
force, or that corporate is out of touch and offers no practical help are torn down" when
employees at all levels are given enhanced roles in environmental management. A third
organization reported that heightened responsibility at the facility level made the facility less
dependent on the corporate environmental office.
Improved Procedures and Documentation
Five participants reported that the EMS had led to improved procedures and documentation.
This reported benefit is interesting in light of the fact that it is common for organizations
considering EMS to complain about the level of documentation that is required in ISO 14001.
One explanation for this seeming discrepancy is that organizations see a value in documentation
and written procedures, but they do not want a standard to require what should or should not be
documented. .
Enhanced Regulatory Compliance
Several organizations reported that they had not yet been able to determine if EMS
implementation had actually improved then: compliance management; however, most believed
that having an established EMS would do so in the future. Those organizations which began the
project with well-developed systems (primarily the larger organizations) reported that their EMS
had undoubtedly enhanced their ability to maintain regulatory compliance (three organizations
reported this). As one large organization summarized: "Our EMS provides the process whereby
environmental laws and regulations are analyzed, guidance is provided, practices are
implemented, and performance is audited. The reports from the audit feed our continuous
improvement cycle." The three organizations which reported these benefits had realized many of
them before participating in the project; thus, the benefits may be more likely a result of having
an EMS in place than a result of implementing one.
28
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Improved Environmental Performance
The ISO 14001 Standard defines environmental performance as "measurable results of the
environmental management system, related to an organization's control of.its environmental
aspects, based on its environmental policy, objectives and targets." Although this definition was
developed through a broad consensus process, there is still no universally shared definition of
environmental performance. However, it is probable that most people generally view
environmental performance in terms of an organization's ability to maintain compliance and/or
reduce emissions, effluents, and Other causes of detrimental environmental impact. It should be
noted that project participants were hot asked to consider any particular definition of
environmental performance in reporting how their EMS influenced environmental performance.
Five organizations reported that they had realized improved environmental performance due, at
least in part, to implementing their EMS or having one already established (several others,
particularly those in the earlier stages of implementation, believed that an EMS would lead to
improved performance in the future). Examples from different organizations are provided below.
• Fifty percent reduction in the quantity of hazardous waste .generated over a five year
period (this benefit was realized before the demqnstration project).
• Improved emergency preparedness and response procedures (this occurred during the
project).
• Identification and implementation of two specific pollution prevention projects involving
materials substitution (this occurred during the project).
Reduced Environmental Management Costs "
Most organizations reported that it was very difficult to determine if the EMS was responsible for
a net reduction in overall environmental management costs (it is likely that an organization's
EMS would need to be in place for a significant amount of time before the organization could
measure costs-savings). However, a few participants did cite specific cost reductions in a
particular area due to EMS activities. For example, one organization reported a 74% reduction in
hazardous waste disposal costs over the period of the project.
Access to International Markets ,
At the end of the Demonstration Project, participants reported that the EMS had not yet opened
or maintained an opportunity in international markets. This finding is consistent with the fact
that market forces for international EMS registration have not yet developed. One organization
said that it was actually skeptical of the trade benefits of ISO 14001. This organization had
' ... .. '• . v •'.,. ' '.29 '• : '
-------
originally implemented ISO 9000 primarily for trade reasons, but ISO 9000 registration had not
resulted in the competitive advantage that the organization originally anticipated.
Costs of Implementation ,
The major cost of implementing an EMS is staff time. If an organization chooses to have an
outside consultant perform a large portion of the work, consulting fees might also be significant.
Other costs might include travel (if, for example, corporate staff are actively involved with an
off-site facility that is developing an EMS), EMS auditor training, and computer software.
Additional costs might be incurred if an organization decides to pursue EMS registration or have
a baseline assessment conducted. ..''•-.
Fewer than half of the participants specifically tracked the costs of EMS implementation, and
only two (both large companies) actually reported estimated costs. Several organizations noted
that they did not track the costs of EMS implementation because it was not established as a cost
center — it was simply considered a part of doing business. Those that did track costs included
different items in their cost calculations. For example, some organizations only tracked
consulting fees and training, while others only tracked staff time.
One participant reported estimated EMS implementation costs in some detail. Costs were
estimated for 12 facilities from the. beginning of implementation (spring 1995) through initial
registration (around the spring of 1997). Since the estimate only pertains to EMS
implementation, it does not include the future costs of EMS maintenance or registration
surveillance audits. Table VI below shows categories used by this organization in estimating
costs. It is important to note this is only one example from the 18 organizations participating in
the project, and should not be interpreted as a "typical" case.
30
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Table VI
One Company's Estimation of EMS Implementation Costs
**''.»•» ~
Corporate """*
Costs' \ * -f
Costs per
Facility
Total Costs:;,
Corporate-*-
12 facilities
"Personnel
-Costs -
Individaal '<:'
iiuimgfcrh ^.
$95,000
includes salary
and overhead
$17,000
includes salary
and overhead
$299,000
Personnel •
Costs
A "
Cross Functional
MgmLTeam
NA .
$25,000
includes salary
and overhead
$300,000
Travel,
$75,000
5 annual site
visits per
facility, one
person for 2-3
days
$5,000
includes
seminars and
auditor
training
$135,000
Materials
$5,000
includes
handbooks,
training, }
supplies, etc.
$2,500
includes
handbooks,
training
supplies, etc.
$35,000
Registration
NA
$25,000
based on costs
of ISO 9002
registration
$300,000
Total: $1,069,000 corporate-wide, or $89,000 average per facility
Barriers and Keys to Successful Implementation ,
Even with the commitment of upper management, implementing an EMS can be a challenging
effort, particularly for organizations that,have few ISO 14001 elements in place or are unfamiliar
with management system concepts. •'.'"-.
Project participants cited several barriers to implementation. By far the most commonly cited
barrier was lack of time due to competing priorities (nine organizations reported this); as will be
discussed later, lack of time tends to be a greater concern for SMEs. Other barriers cited include:
insufficient support or lack of understanding from top management; .
• " insufficient resources; >
• uncertainty about the intent of ISO 14001; and
• • an aversion to added documentation and paperwork (a few organizations reported that it
was difficult to convince the organization to add procedures and documentation to a
system already perceived as quite-successful in maintaining compliance).
31
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A few central themes on keys to overcoming implementation barriers emerged during the group
meetings and in participants' responses at the conclusion of the project. They are discussed
below.
Secure Top Management Commitment Early in the Process
Without top management commitment, the resources and support necessary for EMS
implementation is much more difficult to obtain. Although some participants had obtained a
strong commitment from upper management before participating hi the project, others struggled
to obtain the necessary support throughout the project.
Gain a Thorough Understanding of ISO 14001 ,
Several participants reported that they came to truly understand the intent of ISO 14001 only
after several months of study, discussions with co-workers and colleagues, and attempts to
implement some of its requirements. One participant reported that it was more stringent on its
final self-assessment than on its initial self-assessment because it had developed a better
understanding of the Standard over the course of the project. Based on the self-assessment
results of the individual organizations (three showed no progress, or negative progress, over the
course of the project), it is likely that other participants had similar experiences.
Perform a Thorough Self-Assessment .
A thorough self-assessment of the existing EMS is necessary to provide direction for
implementation. Many participants found it helpful to use a consultant or other external
assistance in performing the assessment, or in reviewing the protocol and results of the
assessment. As evidenced by the results of the independent assessments, this external objective
review can be important to obtain a more neutral view of the organization's existing EMS and to
provide an additional interpretation of the EMS standard.
Involve Many Functions and Staff Levels in the Planning Process'
Several participants reported that one of the keys to successful EMS implementation was
involving representatives from different parts of the organization. This cross-functional
involvement not only brought different expertise together, it also facilitated consensus and
acceptance from the organization as a whole. Many participants (both small and large) formed
teams that included employees from manufacturing, marketing, the ISO 9000 program, and other
functions. Several participants found it very helpful to include employees from the shop floor
because of their intimate knowledge of processes and environmental aspects. Most teams in
32 . • -
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organizations with multiple facilities were comprised of both facility and corporate employees.
. Initially, Set a Small Number of Achievable Environmental Objectives
Some participants reported that setting a limited number of objectives initially helped them
overcome considerable resistance to EMS implementation. One organization, for example,
decided to set and achieve a few simple but meaningful pollution prevention objectives before
developing most of its EMS documentation. This approach was intended to avert the possibility
of employees being discouraged by the need to write numerous procedures (it was also intended
to convince management that providing resources for the development of procedures was
worthwhile). The organization reported that setting and accomplishing the pollution prevention
objectives brought a great deal of satisfaction to the employees involved.
Build on Existing Business Practices '
One approach to overcoming resistance to change is building on successful ways of doing
business. For example, one participant noted that although there was fairly limited
environmental awareness in the organization, there was widespread understanding and
acceptance of basic TQM principles. After failing at first to promote the EMS concept in its .
entirety, the-organization chose to introduce a few environmental objectives — "disguised" as
quality objectives — through the TQM system. Once these objectives were accepted in the
organization, it became easier to ask employees to write plans and procedures to address them..
Links with ISO 9000 and Health & Safety
As previously mentioned, most project participants have facilities that are either registered to ISO
9000 (ISO 9001 or 9002) or working towards registration. Only two participants reported that
they were neither registered nor pursuing ISO 9000 registration. Generally, those organizations
which came into the project with ISO 9000 experience had an easier time convincing others
internally of the value of an EMS., Having the ISO 9000 system established or under
development meant that the organization was familial- with the concept and benefits of
management systems. •''.'.''
Some participants cited specific ISO 14001 elements that had been (or would be) modeled after
analogous elements in the ISO 9000 system. They anticipated that modeling certain ISO 14001
elements after existing ISO 9000 elements would produce significant cost-savings for EMS
implementation. A collective list of those ISO 14001 elements is provided below:
• Training, awareness and competence , ' '
• EMS documentation
33
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•
Document control
Operational control
Monitoring and measurement ,
Nonconformance and corrective and preventive action
Records
EMS audit
• Management Review
Seven participants reported that they would integrate at least some elements of ISO 9000 and ISO
14001; however, at the end of the project only a few reported that they intended to create one
fully integrated quality and environmental management system in the near future. One barrier to
integrating the systems is that the individuals responsible for ISO 9000 within many
organizations are often not knowledgeable of environmental management, and in turn,
environmental managers often lack an understanding of quality management. Because of this,
several organizations reported that it took considerable time to establish links between the
environmental and quality programs.
i . ',
There can be other constraints to system integration as well. For example, one organization, after
carefully exploring its options about ISO 9000/14001 integration, decided not to combine the two
systems because of a concern that (1) integrating incomplete EMS requirements into the ISO
9000 system could jeopardize their ISO 9000 registration; and (2) many procedures under the
existing 9000 system were not appropriate for environmental issues. The observation made
during the independent assessments regarding the separation of the environmental management
staff from the ISO 9000 staff confirms that significant barriers exist to integrating the two
systems. ,
Regarding health & safety, six participants reported that they intended to integrate ISO 14001
with their health & safety program. This is a logical step for those participants that came into the
project with then- environmental, health and safety programs already integrated. One
organization plans to fully integrate its ISO 9000, ISO 14001, and health & safety systems in the
long term.
Comparison of SMEs and Large Organizations
As Table I depicts, the 18 organizations that participated in the EMS -Demonstration Project were
categorized as small, medium, or large entities. The participating organizations include four
small, four medium-sized, and ten large organizations. Categorization was based solely on the
number of individuals employed by the organizations. An organization with fewer than 250
employees was categorized as "small"; an organization employing between 250 and 1000
individuals was categorized as "medium-sized"; and an organization with more than 1000
employees was categorized as "large". The number of individuals employed by the organization
as a whole was considered (not just the number of employees in a particular facility). No attempt
'.34
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was made to consider Standard Industrial Classification (SIC Code) or revenue in categorizing
project participants. . ' .
Some of the differences between Small and Medium-Sized Enterprises (SMEs) and large
organizations are analyzed below. Differences discussed included: motivation to implement an.
EMS, barriers, and potential SME advantages. Information from eight SMEs and eight large
organizations was considered. (Note: this section on SMEs draws on a slightly different data set
than other parts of Section V. It includes information from two additional organizations that
were not included in the analysis done for the other sections).
Incentives for Implementing an EMS .
SMEs and large organizations cited certain incentives in fairly equal proportions. For example,
four large organizations and four SMEs stated that a desire to gain a competitive advantage was
an incentive for implementing an EMS. Likewise, a desire to achieve EMS registration and gain
regulatory flexibility were cited as incentives by equal numbers of SMEs and large organizations.
Other incentives, however, were not cited by SMEs and large organizations in equal proportions.
Of the eight SMEs, four reported a desire to achieve more cost-effective or enhanced compliance
as an incentive for implementing an EMS, and three SMEs stated that a need for better
documentation and procedures was an incentive. None of the large.organizations stated that
"enhanced compliance" or a "need for better documentation" were incentives. In addition, four
large organizations — but only one SME — reported that improved environmental performance or
the desire to 'benefit from pollution prevention opportunities were incentives. These findings
suggest that SMEs may be more motivated to implement an EMS because they want to enhance
their compliance management and improve their documentation, while larger organizations may
be more satisfied with their compliance efforts and documentation and are ready to focus on
pollution prevention. . .
Barriers ,
'.'.-. • ; '.-.'.'- . • • .1 •
Ten participants reported that a lack of time (due to workload and production priorities) was one
of the greatest barriers to implementing an EMS; seven of the eight SMEs reported this, while
only three of the eight large organizations did. Moreover, four organizations (all SMEs) found
that a lack of resources, including funding, was a significant barrier, and two SMEs reported that
the allocation of human resources was a significant challenge. In addition to the time and
resource barriers, the SMEs reported several of the challenges that were also mentioned by the
large organizations (e.g. interpreting the ISO 14001 Standard; achieving detailed documentation;
promoting EMS concepts to management and employees; and training employees). This
suggests that SMEs and large organizations share many of the same challenges in implementing
an EMS, but that SMEs are more challenged by a lack of time and resources.
35
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One large organization in the project'fotind that it took the organization a great deal of time to
understand the Standard before it was willing to invest time in EMS implementation: This
participant stated, "Our organization dealt with this barrier in a manner which, unfortunately,
smaller organizations cannot do without hiring outside consultants/" In this case, the corporate
staff invested time in understanding the Standard, and then disseminated guidance tools and
information to personnel at the facility.
Potential SME Advantages
Some project participants also found that an SME can have certain advantages over a large
organization in implementing an EMS. For example, an SME may be able to develop an EMS
that is less complex than one that might be .appropriate for a large organization. In addition,
employees in SMEs often "wear many hats;" i.e., they have multiple functional responsibilities.
In an SME with ISO 9000 experience, for example, the individual responsible for the quality
system may also be responsible for implementing ISO 14001. In a large organization, however,
the employees responsible for the quality system are more likely to be separate from the
environmental staff. .
Certain requirements in ISO 14001 might be easier to implement in an SME than in a large
organization. For example, two SMEs noted that the Structure and responsibility requirements
in ISO 14001 are simpler to achieve hi an SMEs than in a large organization, since an SME
typically has a less complex hierarchy. Other parts of an EMS that may be simpler for an SME
include training and internal communication.
Recommended Guidance and Implementation Tools
Based on the experience of the Demonstration Project, it has become evident that certain types of
guidance are very important for organizations of all types and sizes attempting to implement ISO
14001. These include:
• clarification of the intent of the ISO 14001 Standard;
• a checklist or other tool to conduct an EMS self-assessment;
• guidance on how to identify and assess the significance of environmental aspects and impacts;
• a step-by-step implementation guide;
• examples of EMS manuals, policies, and procedures; and
• EMS implementation case studies.
These are each discussed below.
36
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Clarification of the intent of ISO 14001 * .
The most commonly asked questions from project participants revolved around the intent of the
ISO 14001 Standard. They want to know what the authors intended in the language of the
Standard, and how registrars will interpret it. Although interpretation of the Standard is
necessary for organizations to move forward with implementation (and particularly registration),
creating a single authoritative interpretation of the Standard may be problematic. SubTAG 1 of
the U.S. Technical Advisory Group has established a formal process to respond to questions
submitted by interested parties about the interpretation of the ISO 14001 Standard. SubTAG 1
intends to issue answers to questions based on the SubTAG's consensus interpretation of the
Standard. A list of interpretation concerns submitted by project participants is provided in the
next section of the report. .
A good way to understand the intent of ISO 14001 is to read EMS implementation guidance
documents, such as ISO 14004 ("Environmental management systems — General guidelines on
principles, systems and supporting techniques"). Another useful document is the guidance for
small and medium-sized organizations developed by NSF International, which is discussed
beloW. . ->. .
A Checklist or Other Tool to Conduct art EMS Self-Assessment
One of the first steps for an organization considering implementation of ISO 14001 is to conduct
an initial assessment of its current environmental management practices. Prior to the EMS
Demonstration Project, NSF International developed a user-friendly checklist to help
organizations compare their existing environmental management practices to the requirements of
ISO 14001. Participants used the checklist in the Demonstration Project, and NSF received
positive feedback on its use. Other organizations, including the Global Environmental
Management Initiative, have also developed ISO 14001 assessment tools.
Guidance on How to Identify and Assess the Significance of Environmental Aspects and Impacts
ISO 14001 encourages organizations to move "beyond compliance" through continual
improvement and pollution.prevention by identifying environmental impacts and setting
objectives to address them. In the past, many organizations conducted environmental planning
solely in response to regulatory requirements, or addressed environmental problems on an "ad
hoe" basis. Thus, systematic identification and prioritization of environmental aspects (and
. resulting impacts), including those not regulated, is a new process for many organizations.
, NSF's implementation guide provides broad guidance on environmental aspects and impacts, but
, more detailed guidance for organizations appears to be needed.
'37
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A Step-by-Step Implementation Guide
Many organizations, particularly those that do not have much experience with EMS,, need to seek
outside expertise to help with the planning process and implementation. However, for smaller
organizations, which may not have a corporate environmental staff, this assistance is often
unavailable internally and too expensive to secure from a consultant. Through an EPA grant,
NSF has developed "Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations" that provides step-by-step implementation assistance and
sample worksheets and procedures (although the Guide is directed toward SMEs, it is just as
useful for larger organizations). The NSF document, along with other implementation guides
that are either available now or will be soon, will hopefully help to satisfy the need for cost-
effective step-by-step implementation guidance. • .
Examples of EMS Manuals, Policies, and Procedures
Most project participants requested examples of EMS manuals, policies, and procedures.
Commonly requested items included: environmental, policies, procedures for identifying aspects
and impacts, monitoring and measurement procedures, auditing procedures, etc. An EMS
manual, although not explicitly required by ISO 14001, can be a useful tool because it provides a
concise overview of the system.
EMS Implementation Case Studies
Organizations considering the implementation of ISO 14001 can benefit from learning why other
organizations implemented an EMS, as well as their experiences with implementation. As mo:re
organizations implement and become registered to ISO 14001, many case studies should become
available. However, at present relatively few organizations have attempted to implement ISO
14001, and thus the experiences of these few organizations are particularly valuable. This report
contains self-written case studies from 17 of the 18 organizations that participated in the
Demonstration Project. CEEM, Inc. has also published a collection of EMS case studies.
Participant Feedback on ISO 14001
According to ISO rules, each ISO standard must be updated every five years. Over the next few
years ISO 14001 is likely to be read or implemented by thousands of organizations who will be
able to offer feedback on the Standard. Since the EMS Demonstration Project presents an early
opportunity for this process, each participant was asked to provide feedback on ISO 14001.
'Project participants generally found ISO 14001 to be a sound model for environmental
management. However, most participants expressed at least some overriding concerns about the
38 .
-------
Standard as a whole and/or concerns about specific requirements. The most commonly cited
concern was the potential for auditors to interpret the Standard differently (note: this may be
viewed as a registration concern rather than a concern about the Standard). Other commonly
reported concerns included confusion over the definition of "environmental aspects;" an
overemphasis on documentation; and confusion about whether written procedures are necessary
for particular requirements. Additional comments that were submitted regarding specific
requirements are shown in Table VII.
39
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Participant Advice to Regulators '
Thirteen of the participating organizations provided advice for regulators seeking to use the EMS
approach in their interactions with the regulated community. The most common advice was that
regulators should offer incentives — primarily regulatory flexibility ~ to companies that
implement an EMS. These proposed incentives include: ,
• reductions in reporting;
• reductions in site inspections and audits;
• reductions in fines;
• elimination of penalties and NOVs for various environmental compliance issues; and
• fast-track permitting.
One project participant offered the following advice: "...(W)e genuinely believe that EMS
implementation will improve our environmental performance. In fact, we have seen indications
already that is exactly what is happening. We would invite regulators to confirm that this is so,
and,,then, if satisfied, provide significant regulatory relief to companies with effective
environmental management systems." ;.
Two participants expressed concern about the ability of smaller organizations to afford ISO
14001 registration, and suggested that incentives such as those outlined above be made available
to organizations which have a fully functional EMS but may not be registered to the Standard.
Many participants expressed concern about the voluntary disclosure of self-audits, and expressed
a desire-for a greater level of trust between themselves and regulators regarding this issue.
Several participants indicated that there is a fear of being punished for "doing the right thing" in
self-reporting of violations and nonconformances.
One participant noted the similarities between ISO 14001 and the "Due Diligence" criteria
contained in EPA's final policy on auditing and self-policing - Incentives for Self-Policing:
Discovery, Disclosure, Correction and Prevention of Violations, Jan. 22, 1996 — and expressed
concern about the possibility of this policy becoming a regulation. The participant noted that
there are benefits resulting from reliable guidance for civil penalty mitigation, but there is a
concern that EMS elements, even if not in a specific EMS standard, will become regulation.,
Three participants suggested that regulators provide expertise and assistance to organizations
seeking to implement an EMS. It was suggested that regulators should place more stress on the
value of an EMS to recipients of NOVs and penalties.
42
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VI. CONCLUSIONS
Major Lessons Learned
Implementing ISO 14001 is Feasible in a Wide Variety of Organizations
The experience of the Demonstration Project suggests that an EMS based on ISO 14001 can be
implemented in a wide variety of organizations, but varying amounts of guidance and assistance
are required for different organizations. The main factors mat seem to determine an
organization's ability to implement an EMS are (1) its experience with EMS, ISO 9000, or other
management system concepts; (2) the level of commitment from its top management; and (3) the
resources available to the organization to develop the necessary procedures and documentation.
Whereas some organizations might be able to implement most ISO 14001 elements in a short
time-frame (e.g., one year) with limited outside guidance, others might require much more time
and a substantial level of guidance. SMEs, in particular, will likely require more guidance and
take longer to complete EMS implementation than large organizations. All project participants
found that ,a significant level of effort was required, regardless of how fast implementation
occurred or how much outside guidance was used. • •
Although notable progress on EMS implementation was made over the course of the
Demonstration Project, it is not clear how many participants will eventually become registered to
ISO 14001 or. attempt to implement further elements of the Standard following the project. Since
it will likely take some participants two or more years to implement ISO 14001, follow-up on
these organizations would be needed to determine the time and effort that was ultimately
required. •
Since the organizations in the project participated voluntarily, they might be inclined to be more
successful with EMS implementation than an average sample of U.S. organizations. However,
the wide variety of organizations in the project, and the significant differences among them in
their abilities to make progress on EMS implementation, provide confidence that the findings
from the project reflect what would be the experience of a large cross-section of U.S.
organizations that might attempt to implement ISO 14001. . ;
EMS Implementation Can Bring Concrete Internal Benefits
Project participants reported many benefits from EMS implementation mat were not market- or
trade-related, including enhanced environmental awareness, improved documentation, and
pollution prevention. These benefits were realized within the one year time-frame of the project,
and before any of the organizations had attained registration or complete implementation. This
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suggests that there are-many reasons other than the market and trade benefits of registration to
implement the ISO 14001 Standard. .
Independent Assessments Can Provide an Important Check on Self-Assessments
The results of the independent EMS assessments suggest that organizations might have the
tendency to evaluate their systems higher than would independent auditors. This may be
particularly true for Objectives and targets and the Environmental management program.
The findings from the independent assessments may also have important implications for the
concept of "self-declaration," in which an organization would declare itself to be in conformance
with the ISO 14001 Standard rather than receive an independent audit from a registrar. The
distinction between self-declaration and registration does becomes smaller if the self-declaration
is based on an objective audit from a consultant; hpwever, consultants are not required by
accreditation bodies to maintain objectivity in audits or to have specified qualifications for
conducting EMS audits. . ,
Remaining Questions and Areas for Future Study
What are the Long Term Benefits and Costs of an ISO 14001 EMS?
The Demonstration Project focused primarily on the process of developing an EMS, not on the
benefits and costs of maintaining one. In the future, studies could be conducted which attempt to
measure and .quantify the benefits and costs of maintaining an EMS over time in a variety of
organizations.
Will Implementing ISO 14001 Improve Environmental Performance ?
A question frequently asked is whether implementing and maintaining an ISO 14001 EMS will
improve an organization's overall compliance and environmental performance. The answer to
this question may become increasingly important if regulators seek to use ISO 14001 as a tool to
complement regulatory programs. Although it was not within the scope of this project to
measure environmental performance, the' project provided an opportunity to make several
observations about the relationship between environmental performance and organizations'
motivations for implementing ISO 14001. The brief discussion below is intended to raise
questions about this relationship that might be addressed through future studies.
The extent to which an ISO 14001 EMS will improve an organization's environmental
performance may depend primarily on upper management's commitment to improving
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compliance and performance. It is difficult to argue that a fully implemented EMS will not
improve the performance of an organization struggling to maintain compliance. However, if the
organization lacks upper management commitment to improve, it is unlikely to develop an EMS
in the first place unless itis mandated to do so through contract or market requirements.
Similarly, if the upper management of an organization having a solid compliance record is not
interested in going beyond compliance, it is unlikely that the organization will implement ISO
14001 solely because it wants to motivate itself to move in that direction; in this case, the
organization would be more likely to implement the Standard in order to position itself strongly
in the marketplace. , .
Even if an organization's motivation for implementing and maintaining an EMS is market-driven
and not performance-driven, it's certainly possible that the EMS, once in place, could lead an
organization to recognize the environmental and economic benefits of pollution prevention and
. other proactive activities. If this were to occur, the organization might begin to set and meet
environmental objectives and targets that go beyond compliance. Thus, an organization might
not be initially motivated to implement ISO 14001 because ofa desire to improve performance,
but the EMS could lead to improved performance once established in the.organization.
The nature of the relationship between EMS implementation and environmental performance
cannot be known until a substantial number of organizations of different types and sizes .
implement the ISO 14001 Standard. In the future, studies could be performed examining~the
relationship between management systems, management attitudes, and particular performance
.parameters.
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VH. CASE STUDIES
Participants in the EMS Demonstration Project were asked to write case studies of their own
experiences with the project .and EMS implementation. The case studies are important because
they convey how the individual organizations view EMS and ISO 14000; they also constitute the
only part of the report in which information associated with specific companies is presented. All
participants submitted case studies for inclusion in this report, with the exception of Prime
Tanning Company.
All but two of the case studies were written by the organizations and edited by NSF International
(the case studies for Hach Company and Milan Screw Products, which were adapted from NSF's
EMS implementation guide for small and medium-sized organizations, Svere written by NSF).
The primary purpose of the editing process was to create a uniform format for the case studies.
Although the case study formats are not identical, most contain the following sections:
Background, Drivers for Implementing an EMS, Self-Assessment, Implementation, Benefits,
Challenges, and Final Thoughts.
Notes on the Case Studies •,
• Several case studies refer to NSF 110, an interim EMS standard developed by NSF
International prior to the development of ISO 14001. - As discussed in Section IV, both
NSF 110 and the ISO 14001 draft were used in the initial self-assessments. .
• The terms "registration" and "certification" are used interchangeably in the case studies.
Essentially, the terms have the same meaning. The difference is that in the U.S., the term
registration pertains to management systems (i.e., ISO 9000, QS 9000, and ISO 14001),
while certification pertains to products. In other countries, certification pertains to both
management systems and products.
Some of the case studies refer to "percent of EMS requirements in place," or "percent of
EMS requirements complete." Please refer to Section IV for an explanation of how this
type of information was generated through the self-assessments.
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3M Corporation
Background
3M, based in St. Paul, Minnesota, is a $14 billion, multinational firm with over 50,000 products.
These products are manufactured by over 40 business units operating in more than 300 locations.
Globally, 3M has 69,000 employees and operations in more than 60 countries.
3M has long been recognized as an environmental leader that manufactures innovative, high
quality products. Approximately 200 of 3M's facilities worldwide have been registered (or are in
the process of being registered) to the ISO 9001 or ISO 9002 Standards.
Drivers for Implementing an EMS
More than 30 years ago, the need to address potential environmental issues at the corporate level
was recognized within 3M. The company's commitment to the environment was formalized
when the 3M Board of Directors adopted the Corporate Environmental Policy in February 1975.
This policy, which remains unchanged today, was crafted long before most companies had
developed such policies.
\
A highly successful waste minimization program known as Pollution Prevention Pays (3P) was;
launched in 1975. Today, the 3P program continues to encourage employees to find innovative
ways to minimize wastes and reduce costs. The 3P program has prevented 1.4 billion pounds of
pollutants from entering, our environment while saving the company 750 million dollars that
would otherwise have been spent on pollution control and wasted resources: 3P continues to be
an internationally acclaimed model waste minimization program. The corporate environmental
organization (Environmental Technologies and Services (ET&S)) has initiated numerous
additional environmental programs for managing other specific environmental aspects (e.g.,
underground tanks, asbestos, air emissions, etc.) on a global basis. These efforts have
substantially reduced wastes and emissions and move 3M towards sustainable development.
3M's corporate ET&S staff viewed the EMS Demonstration Project as an opportunity to gain
experience in formalizing an environmental management system (EMS) at a 3M facility and to
increase 3M's institutional knowledge of EMS reviews.
The 3M Dental Products facility in Irvine, California volunteered to be the pilot site for the EMS
Demonstration Project. The Irvine site's interest in pursuing ISO 14001 is'a natural outcome of
their business and environmental culture. Irvine has the strong management support essential for
an EMS to be successful. The site, which employs 240 people, manufactures and markets over
700 products used hi dental offices and orthodontic laboratories worhiwide. The Irvine facility
was the first 3M facility to obtain ISO 9001 registration. The site also has been working through
the Malcolm Baldridge Award process at the state and national levels. Due to the nature of its
products, the 3M Dental Division also has significant involvement with the US Food and Drug
Administration.
The Irvine operation's primary customers are dentists. The division has significant export
markets beyond North America (including the European Union, Pacific Rim, South America, and
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Africa). Products manufactured include dental restoratives (such as aesthetic filling materials for
teeth), dental adhesives, caps, and impressioning materials used in making bridges and crowns.
Self-Assessment
The initial EMS review was conducted in May 1995. The NSF self-assessment tool was used to
conduct an evaluation of the site's existing EMS versus the requirements of ISO 14001.
Potential ISO 14001 linkages with existing ISO 9000 requirements were identified, and the
development of an implementation guide for use by other 3M locations was initiated.
The review team consisted of three 3M ET&S staff members (the Quality Manager, Auditing
Supervisor, and a Senior Environmental Auditor), a 3M Corporate ISO 9000 Quality Manager,
and an independent environmental consultant familiar with the NSF and ISO environmental
management standards. Three preliminary site contacts (the Environmental Engineer, Safety,
Health and Environmental Manager, and ISO 9000 Quality Manager) were heavily involved in
the initial assessment.
Implementation
Independent of the development of ISO 14001 and the EMS Demonstration Project, 3M had been
moving towards more formal documentation of its EMS. In 1994, a formal EMS was initiated •
for 3M's international locations and discussions were initiated for implementing this process on a
global basis. The 3M vision and mission statement are as follows:
Vision: "3M practices sustainable development by continuously improving the
environmental performance of our products and processes." - -
Mission: "The EMS will ensure compliance to global regulations and 3M policies and will
facilitate continuous improvement of environmental performance."
Once the initial self-assessment was completed (including a written report assessing observed
gaps), internal division resources were used to review the identified gaps, define an
implementation plan, and .close each gap. A Gant chart was used to ensure that the
implementation plan described a logical sequence of events (for example, you cannot conduct an
EMS audit until you have identified and defined all of the EMS elements and have trained
auditors).
Although follow-up efforts were primarily the responsibility of the Irvine site, the facility also
utilized division-level resources. For example, a division representative trained in ISO 9000
auditing had significant involvement in the development of the EMS documents. A team
consisting of two site employees and one division employee spent six and one-half months
preparing EMS documentation. Since there are major similarities between ISO 9000 and ISO
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14001, eight of the 22 documented EMS procedures came directly from Irvine's ISO 9001
Quality Manual. These procedures were in the areas of:, ' . •
* training, awareness, and competence
* management system documentation
• document control -
• monitoring and measurement (calibration of equipment for both process and test)
• nonconformance (corrective and preventive action/root cause analysis and closure)
• records (identification and retention) , -
• management system auditing (internal and external)
• management review
In addition to writing a site-specific Environmental Management Systems Policy Manual, a total
of 22 Standard Operating Procedures (SOPs) were written to address all areas of ISO 14001.
The ISO 14001 certification audit occurred in June 1996, and the facility received its certification
to the ISO 14001 DIS in July 1996. The registrar used for the ISO 14001 audit was also used by
the Irvine site for its ISO 9001 registration.
Challenges !
The biggest obstacle encountered was hi interpreting the ISO 14001 Standard. While the
Standard describes what should be included in an EMS, it leaves the level of detail and level of.
documentation open to interpretation. Through substantial literature review and numerous
discussions with peers, consultants and potential registrars (as well as internal discussions), an
agreement was reached on 3M interpretations that define our "Practice in Place" for each element
of the ISO 14001 Standard.
Although the site has not seen a reduction in overall environmental costs as a result of the EMS,
neither has it seen an increase in environmental costs. Current estimates are that development
and implementation of the EMS for the Irvine site required approximately 1,200 person-hours.,
covering both facility and division personnel. Much of the effort was spent in interpreting and
understanding the Standard and designing the Environmental Policy Manual. This estimate
includes the time required for SOP documentation and additional EMS training for facility
personnel. Overall costs to develop an EMS implementation strategy and corporate guidance
have not been defined.
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.Benefits
Implementing this EMS model brings a more; systematic approach to managing overall
environmental compliance. The EMS also leads to more direct ownership of environmental
compliance issues by facility operations and potentially reduces reliance on corporate staff.
Through the process of continuous improvement, more focused resource utilization, and issues
management concepts (which are inherent in the ISO 14001 process), further environmental
improvements will occur. Ultimately, this process is a necessary element of 3M's sustainable
development efforts to develop products that meet customer needs and respect the ability of
future generations to meet their own needs.
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Allergan, Inc.
Background
Allergan, Inc. is a pharmaceutical manufacturer of eye care and skin care products. The
company's headquarters is located in Irvine, California and maintains operations worldwide. The
Allergan facility in Waco, Texas was selected to participate in the EMS Demonstration Project.
Drivers for Implementing an EMS
Allergan is pursuing the development of a formal EMS and independent certification under
various worldwide standards for a variety of reasons. These are listed below.
> • . '
• A formal EMS will help the company to, ensure regulatory compliance.
• A high environmental standard is already in place at Allergan.
• Allergan's competitors are preparing to implement EMS standards and intend to become
certified to them.
• Development of a formal EMS might be required by certain governmental bodies if voluntary
EMS efforts by industry are not effective.
• Obtaining permits and approvals from regulatory agencies and communities might be
streamlined if a facility has ISO 14001 or Eco-Management and Audit Scheme (EMAS)
certification.
• Regulatory audits and inspections might be reduced if a formal EMS exists.
• New drug approvals (by the US Food and Drug Administration or Ministries of Health in
other countries) and other required approvals might be streamlined.
• EH&S operations at the facility level should improve over time where a formal plan and
actions are in place for attaining and maintaining certification.
• Adoption of a formal EMS might provide marketing opportunities (by easing the entrance
into new markets).
Self-Assessment :
At the outset of the project, the Waco facility already had a well-developed and formal
environmental program in place. Allergan wanted to test this program against the requirements
of NSF 110 and to determine where improvements could be made. The facility had also attained
ISO 9002 certification and thus had a formal quality process in operation.
NSF supplied an EMS self-assessment tool along with training and guidance on how to conduct
the self-assessment and interpret its results. The site's Facility Management Team and the
Corporate EH&S Team both supported the pilot assessment. Based on this assessment, some ,
minor deficiencies in the EMS were discovered and corrective actions were subsequently
implemented. .
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Since the Waco facility is routinely inspected by FDA and other regulatory agencies, the site was
ready to be evaluated by an external third-party EMS assessor. Allergan contracted with an
assessor to conduct a one-day independent assessment of the Waco facility's EMS. This follow-
up assessment was conducted three months after the initial (internal) self-assessment. The
independent assessor reviewed the facility's environmental manual, which covered the nine
major topics in NSF 110.
Implementation ,
•, - " /'-'-. , • ~ -
Allergan has found that one of the key challenges in implementing a formal EMS is the need to
clearly demonstrate the system's positive benefits. The ability to demonstrate cost savings from
pollution prevention/waste minimization activities helped to improve-the credibility of
Allergan's environmental program. In addition, putting environmental performance criteria into
all job descriptions, performance reviews, and specific management objectives helped to
maintain focus on the environmental area and supported our efforts to integrate environmental
management with other business requirements.
'During the course of our implementation process, we also found that learning to "speak the
language" of other business functions (such as Marketing, Sales, R & D, and Production) was
critical to obtaining and maintaining the support of key business managers. _
Benefits
By providing a structured methodology for evaluating EH&S effects, policies, business and legal
requirements, stakeholder interests, and objectives and targets at the facility level, the , .
demonstration project proved to be very beneficial. Allergan also benefited from the
development of written EMS implementation action plans.
The EMS has also helped to ensure regulatory compliance by providing a methodology for
managing compliance requirements and correcting deficiencies. While the company already had
a compliance process in place, the EMS made this process more formal by tying accountability
and performance to individual employees. In addition, education and awareness related to the
EMS have improved considerably as a result of the project.
Finally, the EMS process facilitated the institution of a formal product design process that
incorporated life-cycle concepts. ,
Challenges
Allergan has identified several issues which might affect EMS implementation and certification.
Two of these are discussed below.
• It is not clear whether an EMS certification for a facility that is part of a larger organization
must "stand alone" on all EMS elements,or whether some elements can be addressed by a
'' • • ' " . ' 'V ;- 52 '•'.'.••-''. •''.--
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corporate function or another facility within the organization. One example at Allergan
would be product design. Allergan's Waco facility is a manufacturing site and has very
little control over product design, including product packaging. It may take several: years of
research and development on a product before the manufacturing facilityls made aware that
a new product will be manufactured at that site. If certain activities or functions are outside
the control of a facility seeking registration, how will a registrar determine if EMS elements
related to those activities or functions have been adequately addressed?
1 The threshold criteria for certification are not clear at this time. Could a facility achieve
certification if all elements of the EMS standard have not been fully addressed? Guidance
is needed to allow companies to make internal judgments as to whether or not a facility is
ready for certification.
Final Thoughts
In retrospect, a one-day review of the EMS by an outside assessor was not adequate to cover all
EMS elements and to show evidence of achievement. Two days should be adequate for this
purpose. In addition, it would be preferable to have two assessors evaluate a facility's EMS,
thereby ensuring a more objective review of the system and allowing for "reality checks"
between the assessors.
As of December 1996, Allergan had received EMS registration at its facility in Westport, Ireland
(the facility was registered to ISO 14001 and IS 310 (the Irish national EMS standard)). Allergan
had also received a recommendation for registration to ISO 14001 at its Waco, Texas facility.
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Commodore Applied Technologies
Background
Commodore Applied Technologies, Inc. is a small publicly-owned company specializing in the
discovery and development of new technologies for the remediation of hazardous materials.
Although small in size (currently the company employs 25 staff members), Commodore can list
among its achievements the only Operating permit for a non-thermal PCB destruction process
granted by the US Environmental Protection Agency. In addition, Commodore's Agent 313™
technology for environmental restoration and remediation was selected by the US Department of
Commerce as one of ten innovative technologies for the Rapid Commercialization Initiative
Program.
Drivers for Implementing an EMS
There are two primary motivations for Commodore to implement an EMS — regulatory
compliance and an anticipated competitive business advantage. Commodore is required under
the terms of its EPA permits to have an EMS. The company believes that an EMS designed to
conform with ISO 14001 would satisfy those permit requirements in a manner that also addresses
the company's other business needs. Commodore further envisions that an EMS will help the
company become more effective at compliance, and expects that companies certified to ISO
14001 will be looked upon favorably by both regulators and customers. Because Commodore is
an environmental business, it was desirable to lead by example in the area of EMS development.
Implementation
Small businesses face many challenges when trying to comply with state and federal regulations
and when competing with larger, more established businesses! We believed that implementation
of ISO 14001, while providing the benefits noted above, would be a considerable challenge for
our company. , . •
Initially, our worst fears were realized. Limited staff and other resources made it difficult to
compose and review the new policies and procedures required to satisfy the ISO 14001 Standard.
Those same organizational limitations left us with a system that was often no more than one layer
deep. Also, due to the size of the organization, the employees implementing the procedures were
also responsible for management review. Additionally, urgent business needs frequently delayed
work on EMS documentation. It began to appear that a task of this magnitude might be beyond
the capabilities of a small business such as ours. While the company continued to have a strong
commitment to an EMS and to the creation all of the procedures and programs necessary to
effectively operate an environmental business, the problem was in backing up that commitment
with action.
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Surprisingly, Commodore found that 'the ISO 14001 Standard actually was the solution to our
EMS development challenge — that is, by using the ISO 14001 framework as a template for the
EMS, we found that some of the system design work had already been done for us.
As a small business without a formal management system, it was found that Commodore actually
might have several advantages over a large business with an established EMS, such as:
• building policies and procedures was simplified in a small organization;
• an EMS culture could be built from the .beginning (rather than adding EMS onto an existing
management system); and,
• policies and procedures could be written to follow the. ISO 14001 format the first time,
rather than rewritten at a later date.
In other words, it was not necessary to change a culture at Commodore, rather, we had to create
one. Furthermore, since Commodore has an operational commitment to both ISO 14001 and ISO
9000, it was possible to build all of the system documentation to follow ISO format and ideals.
Using the concepts in ISO 14001, Commodore began to write its environmental policy and
procedures. Since the environmental policy and all of the EMS procedures were new,
Commodore was able to base everything on the requirements of the ISO Standard. By creating
policies, procedures and other EMS documents "from scratch," it is expected that
nonconformities related to the system's documentation and its contents can be avoided.
Final Thoughts
Commodore gained a lot of knowledge and experience from the EMS Demonstration Project.
The opportunity to benchmark with other companies and to share solutions for overcoming
common challenges has been a great advantage in the EMS planning stages.
i '
As with anything new, there are questions that remain unanswered. The most significant relates
to the value of ISO 14000 certification. No one can say for certain what the value of certification
will be. It is hoped that certification will cause regulators to look favorably upon companies
during inspections or incidents. It is also hoped that certification will prove advantageous in the
marketplace. But no one really knows. Nonetheless, Commodore believes that the value is in ,
the doing, and that having an EMS is the right thing to do.
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Fluke Corporation
Background
Fluke Corporation is a global manufacturer of electronic test and measurement instruments,
including multimeters, oscilloscopes and other devices. With annual sales exceeding $400
million, Fluke sells its products in over 80 countries. The distribution of sales is 40% in the
U.S., 40% in Europe, and 20% elsewhere, including Asia. Fluke's worldwide headquarters is in
Everett, Washington, and the European headquarters is in Eindhoven, The Netherlands. Fluke
product development divisions and manufacturing facilities are in Everett, Washington, and
Almelo, The Netherlands.
Fluke is a vertically integrated company, which means that it manufactures many of its own
instrument components, including printed circuit boards, semiconductors and other
microelectronic components, and plastic parts. These processes are the source of large quantities
of hazardous wastes, wastewater (which must be Created prior to discharge), and air emissions
which must be controlled. ,
Drivers for Implementing an EMS
Fluke has been in the process of implementing an EMS since about 1988. The implementation
began with an expansion of the environmental program to include activities which go "beyond
compliance-." These activities include pollution prevention, and integration of environmental
responsibilities into overall business practices. Integration has been achieved by a decentralized
corporate environmental staff. At the same time, environmental issues began to become
recognized as "quality" issues, resulting in integration of the quality and environmental
programs. This realignment has resulted in significant cost savings through more efficient use of
materials, waste minimization, and other activities which directly impact profitability.
With almost two-thirds of its business outside the U.S., Fluke is very aware of the impact of
international standards and directives on its processes, products, and sales. Fluke was the first
company based in Washington State to achieve ISO 9001 certification, in 1993. As a result of
this awareness of the international marketplace, Fluke has been gradually developing an EMS
which will conform to international standards: first the British Standard BS 7750; and now ISO
14001, The primary driver for implementation of an EMS is the market itself, both in terms of
product end-user (customer) expectations, and potential trade barriers.
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Self-Assessment
An initial self-assessment was conducted in June 1995. This assessment indicated that Fluke's
EMS conformed to approximately 55% of the draft ISO 14001 Standard. The major areas that
were not in conformance with the Standard were EMS documentation, formal objective setting,
and self-auditing.
Implementation ,
A long history of progressive environmental management at Fluke, which continues to reap
bottom line benefits, indicates that the existing EMS is highly effective.
In early 1996, Fluke management made a deliberate decision to delay the full implementation of
ISO 14001, and third-party certification, indefinitely. This decision was based ori the fact that
there is no clear indication that customers or others' in the marketplace are requiring certification.
Fluke is currently monitoring customer expectations and international trends in anticipation that
changing trends could lead to a decision to certify to the ISO 14001 Standard.
However, Fluke's environmental strategy includes efforts to prevent or overcome environmental
barriers to international trade. This strategy is resulting in continuing efforts to achieve
conformity to ISO 14001. The ISO 14001 manual is in draft form. All documentation for
environmental operations, hazardous waste and wastewater treatment system documents, and
training records, are included in the ISO 9001 program. In addition, linkages between ISO 14001
and existing ISO 9001. documentation are being identified. Fluke's two internal ISO 9001
auditors have attended a one-day ISO 14001 training session, and the current plan is to merge the
ISO 9001 and 14001 programs as much as possible. If and when the decision is made to pursue
ISO 14001 certification, the auditors will receive training in EMS auditing.
Other educational activities are also ongoing, such as participation in local area ISO 14001 work
groups, and subscription to various information sources. In addition, Fluke is actively involved
in a local EMS leadership project, in which representatives from business, environmental
agencies, and public interest groups are looking into the potential benefits of ISO 14001 as an
alternative to traditional "command and control" systems. Finally, Fluke has obtained a proposal
for registration services, and five year maintenance of registration. These costs are included in
the EMS budget for the next two years, in anticipation of the need to become registered on
relatively short notice. " • . - ,
In October 1996, Fluke conducted a third-party baseline audit of its EMS against the ISO 14001
Standard. This audit, which involved extensive documentation inspection and personnel
interviews, provided further clarification of documentation and other requirements which must
be addressed in order to demonstrate compliance with ISO 14001.
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Fluke's expectation is that certification will become a business necessity in the relatively near
future. Based on emerging trends, it is expected that both the U.S. and Netherlands
manufacturing operations will probably receive third-party certification td ISO 14001 by the end
of 1998. .'.'-•'',
Challenges
'''•."..' ' • ' !
Fluke's ISO 9001 registration experience indicated that the company had "over-documented" its
quality management system in anticipation of what was expected by ISO 9001 auditors. Since
the original ISO 9001 certification in 1993, Fluke has been systematically simplifying its quality
program documentation, while maintaining conformity with the Standard. In order to preclude
such "over documentation" for ISO 14001, Fluke will conduct a comprehensive third-party pre-
fegi&ration audit prior to actual application for registration.
Another challenge is to take full advantage of existing ISO 9001 processes. Since there appears
to be a considerable overlap between ISO 9001 and ISO 14001, Fluke sees a definite advantage
in combining these programs, including the internal audits. This will be a major new activity for
the ISO 9001 auditors, who will need considerable EMS training.
Benefits
Even without the benefit of a formally documented program, Fluke has continued to set goals and
make progress on- various pollution prevention and resource conservation projects. These
successes have been possible because Fluke has integrated its environmental policy into the
corporate culture and into many of its basic business practices, and because the link between
environmental issues and quality is well established. The benefits of sound environmental
management are recognized and supported by top management. In addition to management
support, employee team contributions are recognized through quality program rewards and other
recognition programs. ;
Environmental managers at Fluke also recognize that having an ISO 14001 EMS can potentially
cut costs, reduce wastes, and involve employees hi every aspect of environmental management.
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Globe Metallurgical Inc.
Background ,
Globe Metallurgical Inc. (Globe) is a privately-owned producer of silicon metal and specialty
ferrosilicon products. Globe's products are produced in ten submerged arc furnaces at four
manufacturing facilities (located in Beverly, Ohio; Selma, Alabama; Springfield, Oregon, and
Niagara Falls, New York). Globe is the oldest ferroalloy company in the United States and the
largest US producer of silicon metal and specialty ferroalloys. Silicon metal is marketed to the
primary aluminum industry and the chemical industry, and the specialty ferroalloys are used in
the foundry industry. Globe has been recognized by its customers as a quality leader, winning
the first "Malcolm Baldridge Quality Award" for small business in -1988, the "Shigeo Shingo
Prize for Manufacturing Excellence" in 1989, General Motor's "Targets for Excellence" award,
and Ford's'Total Quality Excellence" award.
Drivers for Implementing an EMS
Globe decided to participate in the EMS Demonstration Project after receiving a survey from a
key customer requesting information on our environmental management program. This same
customer also requested that Globe participate in its 1995 Supply Chain Environmental Forum.
Globe also has a customer that has included environmental commitment in its current Supplier
Excellence Agreement. In addition, Globe sells about 25% of its specialty ferroalloys overseas
and, as is the case with ISO 9000, there are indications that ISO 14001 registration could become
a prerequisite for doing business overseas (especially in Europe). Globe believed that the EMS
Demonstration Project would help the company establish an EMS that satisfies its own
requirement for continuous improvement and will meet any future requirements of its customers
or regulatory agencies. - ,
An important consideration hi Globe's decision to develop an EMS is the growth of the
company, coupled with the increasingly complex environmental regulations faced in four
different states. Without a well-designed EMS, Globe felt that a high probability existed that
there would be an inadvertent regulatory violation or failure to meet some other obligation
established by law.
Self-Assessment
At the beginning of the EMS Demonstration Project, Globe did not have a comprehensive EMS
in place. The company's primary focus was on ensuring compliance with environmental
regulations at the federal, state and local levels. Its EMS consisted of an environmental policy
and various programs established at each of the manufacturing plants. That is, each of the four
plants had implemented its own environmental policies and procedures based on state and local
regulatory requirements, rather than on any specific corporate directives.
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The first self-assessment (performed by site and corporate environmental managers) was based
on the environmental policies and procedures in place at the four plants. This self-assessment
was designed to:
• identify what was currently in place at each site; and
• assess what might be transferable from one location to the others.
The scope of the assessment included examination of records, interviews with individuals at each
plant, and a comparison of the resulting data against the requirements of NSF 110. The
assessment indicated that the company had partially implemented some of the elements of NSF
110, but that very few elements had been implemented completely.
The second self-assessment (performed approximately one year later) was conducted by the
individuals responsible for day-to-day environmental duties at each of the four plants with the
assistance of Globe's environmental consultant. The second self-assessment was based on the
ISO 14001 Standard, rather than NSF 110. The basis for scoring in the second self-assessment
was as follows:
• If all four plants had completed an element, that element was scored as complete for the
corporation.
• If only some of the plants had successfully completed a requirement, it was scbred as
partially complete for the corporation. ,!. -
The results of the second self-assessment showed that none of the ISO 14001 elements were
considered successfully implemented, because not all of the sub-elements were rated as
"evaluated and sustained". At the time of this writing (October 1996), we believe that the
company is nearing completion on certain ISO 1400 i elements, but the process is so'dynamic
that it is often difficult to declare that something is really completed.
Implementation
To continue to make progress, Globe is embarking on a four-year program to develop an EMS
that will be fully integrated with its existing quality and safety management system. New
procedures and programs will be developed to fully implement Globe's environmental policy by
consulting with individuals on the shop floor who actually perform the work. The integrated
system will reflect all of the elements of ISO 14001 in case the need for registration develops;
however, Globe has no plans to seek ISO 14001 registration at the present time. It is believed
that lessons learned during the ISO 9002 certification process will facilitate the establishment of
an effective EMS. Some of the key lessons are that employee training and clear internal
cornmunications are critical elements in the development of a successful system. Globe
anticipates that its greatest effort and actual expense will be in the area of personnel training.
All of Globe's plants have received ISO 9002 certification. Where appropriate, the ISO 14001
requirements will be incorporated into the existing management system documentation. Some
•.'•/' . : •'• 60 •• '•'• ' •. . .; ••''.•-.
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elements (such as training, documentation and management review) present obvious
opportunities for ISO 9002/14001 integration. Quality, environmental, and safety issues will
continue to be integrated into work instructions and training so that employees will not need to
learn and maintain multiple sets of procedures. It is also possible that Globe may combine its
environmental audits with quality and safety audits.
Quality, safety, and environment issues have been and will continue to be discussed at Globe's
monthly Quality, Efficiency and Cost (QEC) committee meetings. The QEC committee is
composed of managers from all four plants and from corporate headquarters. These meetings
provide a venue for discussing issues and events, as well as for developing strategies and plans.
Challenges
For Globe, the greatest challenge in the development and implementation of an EMS has been
the competition for resources and the "human engineering" mat must be done to create a sense of
environmental concern within an organization dedicated to production and quality at the lowest
possible cost to its customers. Glove believes that the integration of management systems (as
discussed above) will Help to create and sustain a culture in which environmental management is
an integral part of the job. .
Benefits •
Once the EMS is in.place and effectively implemented, Globe should be able to demonstrate
continuous improvement in the environmental area. As with its quality management system, the
company expects some economic benefits as well. For example, its is expected that continuous
environmental improvement will reduce air emissions. The 1990 Amendments to the Clean Air
Act require monitoring of emission limits and payment of fees based on tons of pollutants
emitted. By reducing air emissions, the company should save money by reducing waste
generation and by limiting air pollution fees. :
In addition, with the interest shown in environmental matters by some of its customers, Globe's
expects that a comprehensive EMS could be a valuable business tool, particularly by retaining
customers and market share.
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Hach Company
Background
-The Hach Company (Hach) is an international manufacturer and distributor of instruments and
reagents for colorimetric testing, with annual sales of over $100 million. Hach manufactures
spectrophotometers, colorimeters, turbidimeters, and portable testing equipment for the water
and wastewater markets. The company manufactures instruments at its headquarters in
Loyeland, Colorado, and has a chemical manufacturing and distribution plant in Ames, Iowa.
Hach is registered to ISO 9001 and is a member of the Chemical .Manufacturers Association's
(CMA) Responsible Care® program.
Drivers for Implementing an EMS
Through the demonstration project, Hach decided to pilot EMS implementation at its Ames
facility.. The Ames facility has approximately 300 employees and faces environmental .
management challenges due to its many chemical production'processes. The Ames facility is the
only Hach facility that is currently participating in CMA!s Responsible Care® program. Hach
decided to implement an EMS at its Ames facility for several reasons. The company felt that a
sound EMS would: 1) provide assurance to the officers, board of directors, and company
stockholders that the company will continue to meet regulatory compliance requirements and is
prepared to handle other environmental issues; 2) provide a framework to maintain support and
resources from senior management to meet environmental objectives and targets;. 3) help create
market opportunities for the organization; 4) be a mechanism to gauge environmental
performance; and 5) help the company to identify its responsibilities beyond compliance in order
to meet the needs of stockholders, employees, neighbors, customers, vendors, and suppliers.
Hach also believes that the EMS provides a mechanism to keep its staff lean and responsive to
the constantly changing needs of me organization.
Self-Assessment
In order to examine the Ames facility's environmental strengths and weaknesses, the facility's
Quality Director performed an initial self-assessment of the EMS. The Quality Director
reviewed the NSF. 110 EMS Standard and interviewed the Environmental Safety and Health
. (ESH) staff at length. The Quality Director, determined that the facility's EMS conformed with
approximately 30% of the requirements of NSF 110, which was consistent with the expectations
of the ESH staff at that early stage of EMS implementation. The assessment process provided
the ESH staff with a benchmark from which they could measure progress as they continued to
improve the facility's EMS.
After the initial self-assessment performed by the Quality Director, the ESH staff performed an
informal interim audit. The Quality Director then performed a second formal audit of the EMS
(using ISO 140Q1) after one year of implementation. The ESH staff was pleased with the audit
process because the quality management system (QMS) staff had extensive experience in
''-'.••'"•'• 62 .•''"' '. -'--.''•
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auditing management systems. The Quality Department acted as an independent party and
performed a very thorough audit. The Quality Department has stressed that the ESH staff must
document how they do things. There were times when an EMS element was in place but needed
to be documented. • .
Implementation
Hach Company had previously developed an environmental policy, but developed additional
policies to fulfill CMA's Responsible Care® program and the policy requirements of ISO 14001.
Hach Company has issued its Corporate Environmental and Safety Policies to address continuous
improvement, periodic assessments, product stewardship, regulatory compliance, operations,
facilities, and employee health and safety. In addition, the President of Hach Company has
issued The President's Commitment, which expresses top management's commitment to
environmental stewardship and the safety of employees and customers.
In order to determine the Ames facility's environmental aspects, the ESH Department re'viewed
the table of contents of its new ESH manual. The table of contents helped them to develop an
informal environmental effects register and a safety register. The group then evaluated how
environmental regulations affect the company by examining federal requirements (e.g., Clean
Water Act, Safe Drinking Water Act, Clean Air Act, etc.), as well as state and local
environmental regulations. The ESH Department then explored the facility's environmental
aspects and resulting impacts which are beyond those addressed by environmental regulations. A
three- to four-page document was developed that focuses primarily on the facility's operations
and processes and puts less emphasis on aspects such as energy use.
Development of the environmental effects register facilitated the setting of objectives and targets.
While the EMS is still in development, the objectives are focused on maintaining compliance and
tackling issues that had been previously unresolved. One particularly important environmental
issue for the company is determining the impact of its chemical products on international
customers, since 35% of the company's products are sold internationally. These product-related
impacts will be given more consideration when setting objectives and targets in the future.
The ESH staff maintains access to copies of federal and state regulations, manuals, journals, on:
line resources, and software packages that help them to keep abreast of all pertinent
environmental regulations and statutory requirements. While the company has always been very
good at maintaining regulatory compliance, the new EMS procedures for legal and other
requirements have helped to make compliance activities more focused and efficient Procedures
designed to ensure compliance have been properly documented and will protect the company in
the event of employee turnover. The ESH staff at the Ames facility is developing extensive
written procedures to address compliance activities that are sometimes above and beyond those
required by ISO 14001.
Hach believes that the structure and responsibility requirements of an EMS are simpler to
achieve in a medium-sized organization than in a large one. The staff at the Ames facility has;
been given the autonomy to implement an EMS without extensive corporate supervision. This
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has simplified the process because the lines of communication are shorter arid the EMS can be
focused on the operations of a single facility..
""_•-., - ", - - - . • ' , ' . . ' f , • • •-
The Ames facility has an excellent training program due in part to the commitment of resources
in. this area. The facility has a full-time ESH training coordinator. Implementing the EMS has
.supported the facility's ESH training efforts by helping to define training objectives. The ESH
staff is also developing procedures for all ESH training. The documented procedures will
describe the goals and objectives of training and establish curricula for applicable programs.
Internal communication has improved due to EMS implementation. The ESH staff is working
with members of the site's operations, design, and purchasing departments to set reasonable
environmental objectives and targets that complement other business goals. Environmental
issues are becoming an integral part of the business.
While the ESH staff started to develop an ESH manual in September 1995, the Ames facility is
still in the process of completing its EMS documentation. The ESH manual is somewhat unique
in that it must be able to accommodate the extreme diversity of the site's operations — for
example, the manual must address over 6,500 chemicals used or produced at the facility.
The site's ESH staff includes two college students that are working at the facility to develop
some of the documentation (such as EMS procedures) required for a successful EMS. The
students have been very helpful —- they ask a lot of questions and can explain the procedures
clearly and without jargon. The site has also has run some mock-drills or table-top exercises to
assess the effectiveness of its-procedures.
Because Hach is registered to ISO 9001, the ESH staff has learned valuable lessons from the
QMS staff, including lessons about document control practices. As the ESH staff began \
implementing the EMS, they discovered that the site was not as good at controlling
environmental documents as they had believed. A sound document control system is crucial to a
successful EMS — without it, sooner or later someone will be working from an old version of a
procedure. The document control system is managed electronically by a senior ESH staff
member. • . .
As mentioned previously, the ESH staff at the Ames facility is developing extensive written
procedures to address compliance activities, including those that pertain to monitoring and
measurement. These procedures will be included in the ESH manual. The ESH staff has built
upon the facility's QMS corrective and preventive action procedures to facilitate development
and implementation of the EMS. ^ •
The management review element of the ISO 14001 Standard has not been implemented at the
Ames facility. The facility does not intend to fulfill the requirements of the, management review
element unless the site decides to pursue EMS registration. Hach does-not believe that the
management review process adds value to the EMS unless registration is being sought. Hach
believes that all other elements of an EMS can be implemented without management review.
As discussed earlier, the initial self-assessment showed that the Ames facility's EMS conformed
to approximately 30% of the NSF 110 .EMS Standard. After six months of dedicated
..."•'" • ' ' .-'--" 64 .. '• .
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implementation efforts, the site had successfully implemented approximately 58% of the
Standard, and after one year of implementation it has successfully implemented approximately
71% of the Standard. During this time, the ESH staffs primary goal was to continue to ensure
regulatory compliance. EMS implementation efforts were carried out whenever time permitted.
Challenges
One of the challenges that the ESH staff at the Ames facility experienced during EMS
implementation was driving the EMS down through the organization and up through
management. The ESH function is often viewed as a separate entity in many organizations and
not as an integral part of the business. This perception was initially a barrier to EMS
implementation. ESH is now viewed as a more integral part of operations.
Costs associated with EMS implementation can be difficult to quantify. To date, the most
significant costs have been related to personnel expenditures and office supplies. The ESH staff
at the Ames facility has estimated that if the facility had to start from scratch, EMS
implementation over a two-year period would cost approximately $20,000 - $30,000 per year.
Hach estimates that a company must be willing to commit at least one person-year to
implementation of an EMS, but this will vary from company to company. Some of the costs of
implementation can be hidden but must be accounted for— for example, the Ames facility spent
approximately $5,000 on supplies and printing costs for EMS implementation. Initially the costs
of EMS implementation may outweigh the benefits, but in the long run, an EMS can help prevent
an environmental problem and strengthen an organization's commitment to be a good corporate
citizen.
Currently, there are no plans to integrate the ISO 14001-based EMS and the ISO 9001 QMS at
the Ames facility. The QMS staff has suggested that operating parallel systems is the best
approach for both ESH and Quality at this time. The QMS was adapted from existing procedures
and possibly could be more efficient in some areas, while the EMS developers had the
opportunity to "start from scratch" and develop processes and procedures that may be more
effective and appropriate for ESH issues. In addition, the QMS staff are hesitant about fully
integrating an "immature" EMS into the QMS as this might jeopardize the company's ISO 9001
registration. In the event that Hach chooses to pursue EMS registration, the issue of system
integration will be revisited, because integration could result in synergy and cost-savings for both
Quality and ESH.
Benefits
Hach believes that there are numerous potential benefits associated with implementation of an
EMS (e.g., assurances to stakeholders, a framework to maintain.support and resources from
senior management, market opportunities, a mechanism to gauge environmental performance and
to identify responsibilities beyond compliance). During the EMS implementation process, the
Ames facility began to observe improvements in its environmental performance. For example,
waste disposal costs have dropped 70% in one year. The EMS was a contributing factor to the
cost reduction along with the company's quality focus and continuous improvement efforts.
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Since the EMS has not been completely implemented and the system is relatively new, the
benefits have been hard to quantify. But the company believes mat the benefits are there. The
EMS development process helped to spearhead a major renovation program within the facility
for safety and environmental improvements. Employees have started to ask questions and are
following procedures carefully. In addition, the ESH Department is gaining respect from other
business units. The ESH staff will maintain a focus on compliance and is working closely with
plant managers to minimize the impact of compliance requirements on production. However, the
ESH staff is now in the position to discuss why the company should go beyond compliance and
what the business reasons would be for doing so.
Final Thoughts
Hach has not determined if it will pursue EMS registration. The company will "wait and see" if
market forces (particularly demands from international customers) and potential regulatory
incentives provide sufficient benefits to offset the costs of registration. The company may not
implement the remaining 20-25% of the ISO 14001 ^requirements unless .the company decides to
pursue EMS registration. In the event that the company decides to pursue registration, it will be
relatively easy, to put the remaining elements in place given sufficient notice, time and planning.
While questions remain about the value of EMS registration, Hach has come to some conclusions
about EMS implementation at its Ames facility. Initially there were concerns about how the
EMS would fit with the company's culture, but Hach believes that the EMS has helped to bring
about a positive culture change. The EMS approach is consistent with the company's audit
policies and procedures, because it fosters a systematic approach that lends itself to periodic
evaluation. In addition, the process of evaluating the strengths and weaknesses of the facility's
EMS has identified opportunities for improvement. Hach believes that it has benefited from
assessing and improving the EMS at its Ames facility.
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K.J. Quinn & Co.
r, ' ' ' ' f ,
Background
K.J. Quinn & Co.. (Quinn) is a privately owned specialty chemical company involved in the
' research, development, and manufacture of high performance liquid resins, coatings and
adhesives worldwide. Quinn is comprised of three divisions: the Coatings and Adhesives (C&A)
Division, which manufactures solvent-based, water-based and 100% solid urethane products; the
QureTech® Division, which manufactures UV and E-beam curable products; and the Shoe
Finish Division, which manufactures shoe-related products.
Quinn is working on ISO 9001 certification for both its C&A and QureTech® Divisions and
plans to obtain certification in late 1996. These two divisions are located in one facility and will
be certified together. During the ISO 9001 certification process, the managers involved with
quality, safety, and environmental issues became aware of the developing ISO 14001 EMS
Standard and began investigating whether Quinn should also pursue EMS certification.
Drivers for Implementing an EMS
,( ' : ' • , •
As a chemical manufacturer and formulator, Quinn has significant environmental obligations.
These include the need to comply with an ever expanding set of regulations; the need to develop
more environmentally-friendly products; and increasing demands from customers for assistance
in complying with their environmental, health and safety requirements. Quinn concluded that
implementation of an EMS would improve and properly fpcus the company's efforts to meet its
environmental obligations. As with other businesses today, Quinn operates with a lean
workforce in all areas (including its environmental and safety department) and strives to be more
efficient with the limited resources currently available. The company views the establishment of
an EMS as a process that forces it to better organize its priorities and projects, to identify
problems and potential exposures, and to respond in a proactive manner. It goes without saying
that preventing an incident is much more efficient than simply responding to one.
It was concluded that Quinn would eventually require ISO 14001 certification in order to,
compete internationally, just as companies now need ISO 9000 certification to compete in certain
markets. However, as Quinn was experiencing greater commercial pressures to obtain ISO 9001
certification, the company opted to develop and certify its quality management system first. It
was determined that by implementing the EMS after ISO 9001 certification has been obtained,
Quinn could take advantage of lessons learned from the ISO 9001 experience. For example, the
employees would be knowledgeable about management system concepts and certification
processes. ' , ,
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Self-Assessment ~
Quinn became involved in the EMS Demonstration Project to learn more about the EMS
implementation process and to facilitate the establishment of an EMS for the QureTech® and
C&A Divisions. As a first step, Quinn performed a self-assessment of its current environmental
and safety programs. The company decided to incorporate safety into Quinn's EMS because of
the close relationship and numerous overlaps between safety and environmental concerns in the
specialty chemicals industry. The Director of Safety and Environmental Affairs conducted the
preliminary self-assessment using the tool developed by NSF. The company's officers then
reviewed and commented on the results of the self-assessment. The process was not as time-
consuming as anticipated — approximately 20 to 25 hours were needed to perform a
comprehensive review.
The assessment showed that Quinn should concentrate its efforts toward (1) developing more
formal environmental and safety policies and procedures and (2) improving communications on
environmental issues with its neighbors, customers, and other stakeholders. Efforts to obtain ISO
9001 certification were reflected positively in the EMS self-assessment, especially in the areas of
work policies and procedures, documentation, document control, and training. In addition,
compliance with the OSHA Process Safety Management (PSM) regulation reflected positively in
our processes for evaluation of problems and management of change. It was determined that
many procedures that were originally developed for.compliance with the PSM standard could be,
extended to cover environmental actions not currently addressed by these PSM procedures.
Implementation
With the self-assessment completed, the next obvious step was to implement the changes needed
to bring the program into line, with the requirements of ISO 14001. Although formal EMS
implementation has been delayed until after ISO 9001 certification has been obtained, Quinn
continues to develop elements of its EMS on a case-by-case basis as opportunities arise. For
example, as procedures or practices are developed to meet ISO 9001 or various regulatory
requirements, Quinri considers how these procedures or practices might be modified to help us
meet ISO 14001 requirements at the same time. • ,
The biggest hurdle in the implementation process continues to be devoting the time and resources
necessary to develop the missing components of the system, to improve upon the existing
components, and to maintain the system once it is in place. With the employees working at a
significant pace, this can be a challenging situation, especially in the final push toward ISO 9001
certification.
Final Thoughts
Quinn believes that there are some issues that need to be addressed with regard to ISO 14001,
implementation. In particular, there is the issue of registrar access to compliance audit reports
and the potential impacts of this access on a company's ability to maintain these reports as
privileged documents. .Since conformance with the ISO 14001 Standard would require
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Lockheed Martin Federal Systems
Background
The Lockheed Martin Federal Systems site in Manassas, Virginia has as its mission software
development, hardware integration, and special purpose semiconductor device manufacturing.
The customer base of the site includes the US Department of Defense, other federal agencies (to
include space applications), commercial companies, and foreign governments.
The! Manassas site has a strong historyof compliance in all environmental media. The
compliance posture has continued through two previous owners (IBM and Loral Corporation)
and continues with Lockheed Martin.
Drivers for Implementing an EMS
The site's compliance record reflects a culture of compliance among site personnel; it is this
culture, combined with the interest in continued success in its markets, that generated interest in
exploring ISO 14001. Similar foreign interest hi ISO standards was the driver for the site to
pursue and obtain ISO 9001 certification in 1995.
The site plans to continue its market exploration outside the US. To be successful, this effort
will almost certainly require ISO 9001 and ultimately ISO 14001 certification. The site plans to
seek ISO 14001 certification as soon as feasible, especially because the ISO 14001 Standard was
officially published in September 1996.
Self-Assessment i
To help plan for ISO 14001 certification, we compared the Standard's requirements against the
EMS,that was already in place at the site. We performed an analysis to identify the gaps between
what we had in place and what we needed to meet ISO 14001 requirements. In general, we
found most of the elements were in place, although some enhancements were heeded. Certain
elements of ISO 14001 were essentially complete, such as document control and records
procedures. These were the result of the site's effort in ISO 9001. In fact, the close relationship
between ISO 9001 and ISO 14001 became evident during the gap analysis. The cost of obtaining
ISO 14001 certification is expected to be significantly below that of ISO 9001 because:
• '-' \ ', . • ... ' , =
• existing environmental programs are strong; and
• many overlaps between ISO 9001 and ISO 14001 were identified (particularly in the area of
documentation).
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companies to periodically evaluate their compliance with applicable environmental laws and
regulations, many companies may be concerned about potential loss of audit privilege as a result
of ISO 14001 registration. .
Implementation and maintenance of the EMS will be a challenging task, but a necessary one
which should be very rewarding both in cost-savings as well as in protection of the employees
and the environment.
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Implementation
To satisfy the requirements of ISO 14001, the site environmental program needed to be enhanced
in several areas. Primarily, we needed to formalize a policy statement and document our goals
and objectives. In addition, the site needed to implement a formal environmental assessment
program and strengthen its existing audit program. As part of this effort, we have strengthened
our existing compliance audit program and developed an EMS audit program. The latter is
focused more on our posture relative to ISO 14001. Although the two programs have a different
focus, we feel both are important aspects of the site environmental program. A schedule of
implementation activities is shown below.
Activity
Develop / enhance audit checklists
In-house auditor training for select site personnel
Develop environmental assessment process
Integrate ISO 14001 elements into ISO 9001 program
Formalize environmental policy statement
Formalize environmental objectives and targets
Third-party walk through
External auditor training for two members of the
environmental staff
Conduct EMS audits
Update management review
Third-party initial assessment
Third-party final assessment
Completion Date
August 1996 .
April 1996
May 1996
May 1996
September 1996-
September 1996
September 1996
October 1996
November 1996
December 1996
December 1996
April 1997
Status
Complete
Complete
Complete
Complete
Complete
Complete
Complete
Complete ,
Ongoing
Planned
Planned
Planned
The Manassas site has chosen its current ISO 9000 registrar to conduct the ISO 14001
registration audit. '
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Challenges
Perhaps the biggest challenge of the ISO 14001 implementation process was the need to develop
a business case to justify the required EMS improvements. Making this business case can be
particularly challenging at a site which has historically had a strong environmental program. In
order to sell the need for change, we:
• worked with the site Total Quality Management group and ISO auditors to explore common
system features (and possible benefits to the site of integrating these systems); and
• raised the awareness of site management regarding the potential benefits (both
environmental and economic) of ISO 14001 certification. .
Final Thoughts .
We believe that ISO 14001 offers both an environmental and business opportunity for Lockheed
Martin Federal Systems at Manassas. Through the efforts to formalize and enhance the existing
environmental program, we believe the company will experience greater efficiencies resulting
from: • ;
• proper and current procedures;
• adequate and accurate data collection and calibration systems;
• well-defined processes to ensure compliance with new regulatory requirements; and
• sufficient documentation to allow more efficient coverage when the primary staff person is
not available.
In addition, we believe that ISO 14001 offers a vehicle for approaching regulators to request a
reduction in the frequency of on-site audits and reviews. We also believe organizations should
look carefully at combining their ISO 9001 and ISO 14001 efforts into a single cohesive program
to provide a transparent single program to the site. This feature will also aid in the acceptance of
the total effort by site management.
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Madison Gas and Electric Company
.Background ;
Madison Gas and Electric Company (MGE), founded in 1896, is a public utility located in
Madjson, Wisconsin. MGE generates* transmits and distributes electricity to 120,000 customers
in a 250 square mile area in Dane County, Wisconsin. MGE also transports and distributes
natural gas to 103,000 customers throughout a 1,325 square mile area in seven counties.
In additipn, MGE subsidiaries market non-regulated natural gas and other fuels to large
commercial and industrial customers and governmental institutions nationally.
Drivers for Implementing an EMS
Over the past 30 years, the utility industry has encountered many environmental issues and has
been heavily regulated. MGE initially adopted an EMS to ensure compliance with environmental
regulations. Over time, the EMS has expanded to address new regulatory requirements, concern
of future environmental liability, cost management, competition, audit results, and new corporate
policies, goals and objectives. >• •
MGE's key motivations for implementing an EMS based on ISO 14001 are ensuring regulatory '
compliance, improving the company's competitive advantage, and continually improving
environmental.performance over time. MGE decided to participate in the EMS Demonstration
Project because iiprovided opportunities for: .
' • • . • ' s*. ' ' • • . . ' ' • • ' - ' '-" •' •...•'
• benchmarking its EMS with those of other project participants; and
• learning from the EMS implementation successes and problems of other participants.
Self-Assessment *
As a first step, MGE hired an environmental consulting firm to conduct an independent
assessment of its existing EMS. The results of the independent assessment were reviewed by
company management and compared with earlier informal self-assessments. The independent
assessment showed that MGE was strong in the areas of environmental policy, management
support, provision of resources, among other areas. Some of the elements requiring
improvement included environmental aspects identification, EMS "documentation, and document
control.
MGE found the self-assessment process to be worthwhile. We learned that much of our
environmental program paralleled the ISO 14001 Standard very well; however, certain areas of
our program lacked the depth and detail required by ISO 14001.
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Implementation '
Based on its self-assessment, MGE decided to incorporate the elements of the ISO 14001
Standard into its existing EMS. This decision was based on a goal of full integration of
environmental concerns into the daily operations of the company. The company's Management
Environmental Task Force (MET) and Green Team Leaders (GTLs) were assigned the job of
integrating the elements of ISO 14001 into MGE's environmental program.
The MET, which is comprised of senior managers, establishes environmental policies, performs
strategic planning, and provides resources to the GTLs. The GTLs are the implementing arm of
the MET and represent the company's operating and service departments, including union
representation.
The GTLs decided to focus first on two elements of ISO 14001: environmental aspects (Section
4.3.1 of the Standard), and monitoring and measurement (Section 4.5.1). Working on the
environmental aspects element allowed us to review our operation again and to confirm and/or
modify the basis for our existing environmental program (i.e., the issues or aspects that the
program was designed to address). Working on the monitoring and measurement element
provided a mechanism for communicating, environmental performance to MGE departments and
management. We expect to complete work on these two elements by the end of 1996. Work on
the remaining ISO 14001 elements (as identified through the self-assessment) is scheduled for
completion by the end of 1997. - ' .
MGE has decided not to seek registration to the ISO 14001 Standard at this time. We believe
that registration would have limited value because the company does not currently participate in
the international marketplace. The effort, cost, and time required to develop and maintain the
written documentation required by ISO 14001 would not be offset by the benefits of registration.
However, as more companies become registered, the registration process should improve and
additional registration benefits should be identified. If ISO 14001 does become a standard for
doing business in the future, MGE will be well-positioned for registration.
Perhaps the greatest •difficulty we faced in implementing ISO 14001 was in defining significant
environmental aspects. This element raises a number of critical issues such as determining
which stakeholder concerns are significant, how "significance" should be measured, how a
company ensures that all significant aspects have been identified, and how the process for
identifying significant aspects should be sustained over time.
Benefits
The EMS process resulted in better environmental awareness, which in turn improved the
communication between the company's operating departments and the Environmental Affairs
staff. This has led to a proactive approach to environmental problem-solving whereby MGE can
anticipate problems and develop cost-effective and efficient programs to address them.
Improved awareness also resulted in the implementation of pollution prevention programs.
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Final Thoughts
Environmehtal management has become an integral part of doing business today. The ISO 14001
Standard provides an additional tool for managing a company's environmental concerns in a
cost-effective and efficient manner. A strong EMS can bring competitive advantage by:
" ' " , " •- l
• reducing costs through pollution prevention and waste minimization programs;
• ensuring sustained environmental compliance;
• reducing future environmental liabilities;
• reducing insurance costs; and .
• addressing the needs of customers, shareholders, the community, and regulatory agencies.
In the future, the ISO 14001 Standard may also lead to regulatory incentives, such as fast-track
permits, reduced inspections and fines, and the potential for further partnering of business,
stakeholders, and government in eliminating and controlling environmental impacts.
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Milan Screw Products
Background
Milan Screw Products is a small (32 employee) manufacturing firm located in southeastern
Michigan. The company manufactures precision fittings for the fluid power, automotive, and
refrigeration industries, and is registered to ISO 9002. There are approximately 1,500 companies
in the United States in the screw-machine products industry. Most of these companies are
family-owned and family-managed, and typically have approximately 50 employees.
Drivers for Implementing an EMS ,
There are generally few hazardous materials used in the screw-machine industry, but there are
environmental issues associated with the containment of coolants and cutting oils, the need to
find substitutes for chlorinated solvents, and the disposal of waste oils. The most persistent
environmental challenge is the containment of cutting oil within production machines. Many
screw-machine shops have production equipment that was manufactured in the 1950s, which
may have leaky gearbox covers and inadequate oil splash guards. Failure to adequately contain
cutting oils also creates cleaning and disposal issues, such as stained carpets, solid wastes
(saturated oil absorbents swept from the shop floor), and liquid wastes (solvents and soaps used
in parts or equipment cleaning). The cutting oils also can have health and safety implications.
While it may be simple in the industry to accept the oily film that can coat everything from the
light fixtures to the floors as a "fact of life," Milan Screw Products decided to improve the
management of its environmental issues. Top management recognized that a clear environmental
policy, objectives and targets, written procedures, training, and corrective action (elements
similar to its quality management system (QMS)), would help the company .to proactively
manage its environmental practices.
Implementation of an EMS was motivated by the company's desire to improve its environmental
performance. While progress had been made in the past, the organization was lacking a structure
for its environmental management program and had no means to measure progress. In light of
the company's QMS experience, the EMS approach appeared to be the best way to achieve its
goals. "
Self-Assessment
In March 1995, Milan Screw Products joined the EMS Demonstration Project. One of the first
Steps in the project was to conduct a self-assessment. Milan Screw Products used NSF's self-
assessment tool, which enables an organization to determine how its EMS measures up against
ISO 14001. The company's score was very low because it did not have a formal EMS in place.
However, the low score did not discourage Milan Screw Products; instead, the company set a
goal to fully implement an EMS by June 1996.
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Implementation
One of the first steps in implementing the EMS was the establishment of a cross-functional
.environmental task group (ETG), which consists of five representatives from production,
support, and management. The ETG is responsible for assuring continued regulatory compliance
(including the submission of all permit applications and reports to federal, state, and county
environmental agencies)and improving the company's environmental performance. Milan
Screw Products found that participation of shop-floor employees is essential to the successful
implementation of its EMS because participation encourages employee ownership of the process.
Participation in the ETG has heightened environmental awareness among its members and
enhanced their understanding of the company's environmental responsibilities. In addition,
environmental compliance activities are now being managed effectively by the ETG and require
limited top management oversight.
In order to determine the company's environmental aspects; ETG members first used
brainstorming techniques. They listed'all of the company's inputs (e.g., energy, water), outputs
(e.g., oil mist, noise), and conversions (e,g., steel bars to chips, cutting oils to mist).- The ETG
also examined the company's purchases, processes, and waste streams. Stakeholders were
identified, and some stakeholders were interviewed so that the company could gain a better
understanding of their environmental concerns. These stakeholder concerns were added to the
list of environmental aspects. Once the environmental aspects were identified, the ETG then
rated the probability of an environmental impact occurring and the severity of the impact if it
were to occur. The environmental aspects arid impacts were then grouped into general
categories, such as oil-related problems. , , •
. Based on the assessment of environmental aspects, it became clear that the company's primary
environmental objective should be oil recovery. During the same time period, Milan Screw
Products had been contemplating the need for anew manufacturing facility. The identification of
the company's environmental aspects and impacts provided additional impetus for the
development of a new facility. The identified environmental aspects and impacts and other
elements of the company's EMS have played a significant role in determining how the new
facility will be designed and built. The company will continue to perform oil recovery practices
at the existing shop (in accordance with its environmental objective), but will not set numerical
targets until the new facility has been completed.
Milan Screw Products has found that the structure and responsibility requirements of ISO 14001
are easier to manage in a small company. Milan Screw Products has formed six teams for quality
and productivity purposes. These teams.have been given decision-making authority and have
been effective contributors to the overall management of the shop. Over time, the teams also will
support the company's environmental management efforts. The ETG will continue to spearhead
the EMS program since the company owner, plant manager, quality manager, safety manager,
plant supervisor/environmental coordinator, and a representative from production staff are
actively involved. The key to success in a small company appears to be the team approach, since
small businesses seldom have the luxury of dedicating a person to manage environmental affairs
. on a full-time basis/The team approach also has fostered effective internal communications.
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Finding the time to train employees can be a challenging aspect of running a small business. To
meet this challenge, Milan Screw Products conducts training sessions one half hour before or
after the employees' normal shift. The company also has been quite successful at holding
"brown bag" sessions, where employees bring their lunches, participate in a training presentation,
and remain "on-the-clock" for the.lunch/training period. The company also has videotaped
training sessions to facilitate the training of new hires. The ETG has supported the training effort
by gathering and compiling training materials.
Milan Screw Products has gone beyond the requirements of ISO 14001 by soliciting the Views of
external interested parties. The company has found that an effective external communication
program builds trust. The company has been straightforward with the community about potential
oil problems and the community has been very supportive of the company's environmental
efforts and its plans for the new facility. In addition, communicating about environmental
management issues with its customers has enhanced their appreciation of Milan Screw Products
as an environmentally responsible company and a leader in the industry.
Since Milan Screw Products has a ISO 9002-registered QMS, the company has a sound
document control process in place. The QMS document control procedures will be adapted
where applicable, and the corrective and preventive action procedures will be used in the EMS.
The company intends to utilize some of the lessons it has learned through its QMS about data
collection and monitoring and measurement and apply these lessons to the EMS.
Milan Screw Products has gained experience in management system auditing through
implementation of its QMS. Top management has performed QMS audits with the help of an
auditor training guide prepared by a QMS consultant. The company has conducted in-house
auditor training with the help of the guide and has used the auditor training guide (where
applicable) in conducting its EMS audits. Milan Screw Products plans to continue to integrate its
ISO 9002 QMS with its ISO 14001 EMS, including development of a single manual that will
incorporate both quality and environmental management system elements.
Challenges i
To date, the biggest challenge that Milan Screw Products has encountered has been allocating the
human resources to the EMS project in the face of high production demands. The company has
also had to overcome some old practices by explaining to employees the rationale behind the
changes and the company's desire to successfully implement an EMS.
While Milan Screw Products has not completely implemented its EMS, it has made significant
progress over the last eighteen months. Groundbreaking for the new facility (in June 1996) has
caused the company to shift some of its priorities to support the new construction. The compainy
hopes to fully implement its EMS by April 1997.
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Benefits '
Milan Screw Products believes that there are numerous potential benefits associated with an
effective EMS. An EMS can improve employee retention, new hire selection, and working
conditions, as well as the perceptions of its suppliers, lenders, customers, neighbors, and
regulators. The EMS also can ease management concerns that ah environmental problem could
arise from simple ignorance or lack of training.
It may be difficult to perform a cost/benefit analysis of EMS implementation because some of the
potential benefits are intangible and cannot be assigned a monetary value. It also is impossible to
tally citations that are not written, fines that are not levied, and lawsuits that are not filed.
Milan Screw Products' proactive environmental program has improvedjts stature and fostered
better communication with regulatory agencies. The company will also benefit from being one of
the first in its industry to successfully implement an EMS — this may promote the perception
among customers that the company is more innovative, more responsible, and perhaps more
desirable than their competitors. The company has found that although many of the benefits of
an EMS cannot be anticipated beforehand, they will be discovered as pleasant surprises after
implementation. .
Final Thoughts
i i - **
Milan Screw Products has not determined if the company will pursue EMS registration — that
decision will depend on factors such as costs and customer demand. The company intends to
fully implement its EMS and then evaluate the need for registration next year. Obtaining EMS
registration would be a source of pride and it might improve customer perception of the
company, but the company has not determined whether the costs associated with registration can
be justified. ^
Top management believes that organizations that choose to implement an EMS should not get
discouraged if EMS implementation efforts need to be set aside occasionally. You can start,
stop, and resume your efforts as needed — your aspects won't change unless you change your
processes or products — and any progress that you have made will still be there.
Milan Screw Products encourages other small companies to implement ail EMS. An EMS can
help a small or medium-sized organization to prevent environmental problems from occurring
(rattier than mitigating their resulting impacts), which may keep a small company in business.
An EMS enables an organization to look at its business from another perspective. Many
organizations have considered quality, safety, and other functions as integral parts of their
business, and they should look at environmental management in the same light. Looking at all of
the critical business functions together provides great opportunities for improving the
organization as a whole. ,
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NEO Industries Ltd.
Background
NEO Industries (NEO) is an international service company specializing in the industrial hard
chrome plating'of steel and aluminum mill work rolls. The company, which is headquartered in
Portage, Indiana, consists of small service facilities in North America and Europe that are
strategically located in close proximity to these mills. NEO's core business is the application of
a thin layer of hard chrome to the rollers in the mills. This chrome layer increases resistance to
wear and improves the quality of the rollers' surface characteristics.
Drivers for Implementing an EMS
NEO's business dictates the need for an EMS. Due to, the nature of the processes and materials
employed, NEO has been proactive in the environmental design and operation of its facilities.
An environmental consulting company supported NEO in planning future environmental
initiatives by performing environmental audits of all of the company's facilities.
NEO decided to participate in the EMS Demonstration Project based on a number of
environmental concerns, including: (1) air emissions; (2) handling, disposal and proper
containment of hazardous wastes; (3) employee health and safety; and (4) compliance with local
and federal regulations. NEO also believes that implementation of an effective EMS will
promote market leadership, enhance stakeholder confidence, and help to ensure the public that
the company is effectively managing its environmental obligations.
Self-Assessment
NEO initially selected its Portage, Indiana facility as the pilot location for developing and
implementing an EMS. An EMS self-assessment was conducted at the Portage facility using the
NSF self-assessment tool. Considerable effort was made to ensure that the internal assessors
presented a candid picture of the status of the EMS.
The self-assessment confirmed that NEO had sound environmental practices, the most modern,
efficient equipment available, and excellent environmental design and facility construction.
However, the self-assessment also showed that formal programs and documentation to manage
environmental issues were lacking. The company was proactive in the areas that it knew about,
but did not have formal procedures and training to ensure that the environmental implications of
new issues or conditions were adequately identified and addressed in all cases.
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Implementation
As the project moved forward, NEO realized that the plan to implement an EMS at one pilot site
and then roll the EMS out to other facilities was unrealistic. Given the size of the company, it
was not feasible to dedicate the skilled resources necessary tq,adequately implement an EMS one
site at a time. As a result, NEO shifted away from tackling the EMS as a pilot project at one
plant to organizing a team to pursue EMS for all plants simultaneously. In this manner, NEO
could use skills throughout the organization to support development of the EMS.
During the course of the project, NEO wrote an environmental policy based on NSF 110 and ISO
14001. The NEO policy includes commitments to the principles of compliance, prevention,
communication and continuous improvement. The management team also chose to incorporate
health and safety management into the policy. The NEO Health, Safety and Environmental
Policy has been fully implemented at all of its facilities in North America.
f • . . ' ".
Over time, it became evident that establishing and maintaining a formal EMS would be a greater
challenge than NEO had originally envisioned. NEO held several discussions (both internally
and as part of the EMS Demonstration Project) about the benefits of initiating an EMS once an
ISO 9002 project was completed. This approach has the advantage that the systematic
documentation and procedures needed for ah EMS are similar to those needed for the ISO 9002
quality system. ;
.Although NEO has an excellent reputation for quality and service, it was just embarking on "'
certification to ISO 9002. NEO shifted its priority arid immediately focused oh certification to
ISO 9002. Then NEO utilized this methodology to establish and document an effective EMS. It
feels that experiencing the rigors of ISO 9002 certification will facilitate the development and;
implementation-of an EMS. The two systems will follow a consistent format, and much of the
required training will be used to satisfy both standards. • : .
Through the EMS Demonstration Project, NEO recognized some of the difficulties in developing
an EMS. Withput the-advantage of an existing ISO 9000 system, it lacked some of the
procedures, documentation and know-how that is advantageous in developing an EMS. At the
same time, compliance with new air quality standards and NEO's ongoing need to upgrade
certain processes diverted resources away from EMS development. NEO did not progress as far
as hoped due to the numerous demands of running a business. Hence, NEO can claim only
partial EMS implementation at the close of the project. '
Benefits
NEO has already experienced some of the benefits of EMS implementation and expects to see
other benefits as system development moves forward. First, EMS development has heightened
employee awareness of environmental issues. NEO is more focused on areas that can impact the
environment and Has taken steps to eliminate certain processes that must be controlled due to
their environmental impacts. EMS development has also helped NEO to utilize its resources
(both in-h'ouse and outside) more effectively. -
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NEO anticipates that implementing ah EMS will result in more effective approaches for
managing compliance, especially through documentation of existing and new procedures and
processes. Environmental training will also be formalized and tracked.
Other anticipated benefits include improved employees' attitudes, better financing capability, and
maintained stakeholder confidence. NEO believes that continued attention to environmental
matters has helped (and will continue to help) to retain long-term customers.
Final Thoughts .
The EMS Demonstration Project was an excellent opportunity to learn about the emerging ISO
14001 Standard. The blend of large and small companies, represented by individuals from both
environmental and operational areas, provided participants with broad exposure to the challenges
in implementing an EMS. The environmental consultants who volunteered to participate in the
project were extremely helpful to all participants. The cooperative approach of the EPA and
local officials bolstered the development of the project.
Participation in the EMS Demonstration Project has been of great value to the NEO organization.
The company is more focused on environmental management due to the support of NSF
International, the EPA and the input of other participating companies and sponsors. It has helped
NEO to establish priorities and set a goal for implementing an effective EMS in 1997.
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NIBCO Incorporated
Background
NIBCO Incorporated (NIBCO) is a worldwide manufacturer of fluid handling (plumbing)
products for the residential, commercial and industrial markets. Founded in 1904, NIBCO is a
family-owned Fortune 1000 and Forbes 500 company. NIBCO has a total of 13 manufacturing
facilities, 11 of which are ISO 9002 certified. NIBCO employs approximately 3,200 associates
worldwide. NIBCO is committed to. continued excellence, leadership, and stewardship in
protecting the environment and conserving natural resources. Environmental protection,
including compliance with applicable laws and regulations, is a primary management
responsibility and the responsibility of every NIBCO associate.
Drivers for Implementing an EMS .
In light of constantly and rapidly changing public.expectatidns, community concerns, customer
expectations, and federal, state and local legislative and regulatory activities, successful ;
companies can no longer merely respond to these changes —- they must proactively identify and
manage their environmental obligations. NIBCO realized that.it had to learn how to anticipate
these changing expectations and adopt new ways of providing for continuous improvement in its
efforts to manage environmental compliance and environmental performance. The company
views an EMS as a perfect tool for presenting and supporting its environmental philosophy. The
fundamental driving force behind developing and implementing an EMS at NIBCO was the
desire and need to formally define and put in place the structure, practices, procedures, processes,
and resources necessary to ensure regulatory compliance and continuous improvement in
environmental performance. . .
Implementation _
NIBCO's EMS is focused around two distinct yet intimately connected concepts: Total Quality
Environmental Management and Waste Minimization and Pollution Prevention (WM/PP). In
designing our EMS, the key objective was to expand upon the concepts, tools, and experiences of
our ISO 9002 Quality Management System (QMS), and to apply them to environmental
management, including environmental compliance. This approach allowed NIBCO to integrate
the control, monitoring, and other management aspects of the QMS with the cost savings and
other benefits of WM/PPv Having a certified ISO 9002 QMS was an advantage — our associates
understood what EMS development would mean in terms of resources and time.
The process of developing an EMS involved an in-depth evaluation of the existing ISO 9002
QMS and developing national and international EMS standards (e.g., ISO 14001, NSF 110,
BS7750, and CSA Z750), as well as a review of the company's environmental policy and
environmental objectives. This evaluation resulted in the development of a NEBCO
environmental management standard that meets the requirements of ISO-14001 and fulfills
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NIBCO's environmental policy. This internal standard describes the minimum requirements for
the development and implementation of a formalized, systematic environmental management
program at each manufacturing facility.
The development, implementation, and auditing of the program is directed and supported
internally by the corporate environmental department. The brunt of the work, however, is
accomplished at the facility level by cross-functional environmental management teams. These
teams generally include the plant manager, the plant environmental professional, the plant quality
manager, and representatives from other business functions within the facility, .such as
production, accounting, maintenance, and safety. The application of TQM concepts, combined
with the use of internal standards and the involvement of cross-functional teams, has been the
catalyst for NIBCO's success in its attempts to manage environmental activities.
Benefits ,
Because the company-wide Environmental Management Program emphasizes cross-functional
team building and the importance of problem solving, NIBCO has begun to realize some of the
benefits of an EMS. The most significant benefits have been: improvements in communication;
the increase in environmental awareness throughout the company; the level of employee
involvement and interest in environmental management efforts at the manufacturing facilities;
the realization of environmental responsibility and accountability; and some operational cost
savings resulting from initial WM/PP projects. Other perceived benefits include: reduced
environmental risk and liability; positioning for marketplace advantage; improved compliance
posture and relations with regulators; the ability to benchmark and measure progress using
consistent methodologies; and strategic environmental planning and budgeting.
Challenges
The process of developing and implementing an EMS has not been without its challenges. Initial
barriers that had to be overcome in order to sell the concept of an EMS to senior management
and the manufacturing facilities included: •
!.-•'•
• the fear of increased liability as a result of auditing;
• the cost of technology required to meet NIBCO's policy and objectives; and
• the fear of compromising production.
We communicated to senior management that an effective EMS would help the company to
reduce liabilities and environmental risks, as well as help to achieve other business goals. To
increase ownership throughout the organization, NIBCO educated the workforce about the real
and potential impacts on the environment due to their everyday jobs.
NIBCO found that many sections of ISO 14001 were subject to interpretation, but that no single
element was too onerous to implement. The Operational Control section was perhaps the most
challenging, but NIBCO believes that there is sufficient flexibility built into ISO 14001 for
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companies to tailor their operational control needs based on their actual or potential
environmental impacts.
The EMS implementation process has presented some significant challenges. Some of the
challenges mat NIBCO has faced include: limited time and resources at the site level; obtaining
meaningful cross-functioijal involvement; dwindling inertia; lack of data required to support
continual improvement; development of performance measurements (how and at what cost); lack
of definition of best management practices; and the degree to which the EMS and ISO 9002
QMS can and should be integrated. We had to dispel the notion that "environment is not my
job" and demonstrate that managing our environmental aspects effectively would actually help us
to meet other business goals, such as reduction in downtime.
Final Thoughts
Despite the drawbacks and hurdles of implementing an EMS, the system has provided NIBCO
with: .
• a mechanism to control and manage operational and waste management activities;
• an effective strategy for monitoring ;and measuring our compliance status and promoting
. continuous improvement in environmental performance; and, , .
• a link between environmental management and the ISO 9000 QMS (as well as other
business management initiatives). .
In addition, by increasing the focus on documentation and document control, the EMS provides a
tool to demonstrate to regulatory agencies what the company is doing to ensure compliance.
Combining the concepts of ISO 14001 and ISO 9000 have allowed NIBCO to move toward the
development of a single cohesive integrated management system designed to apply to all areas of
the business, and has given NIBCO another tool for meeting and/or exceeding our customers'
expectations.
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Pacific Gas and Electric Company
Background
Pacific Gas and Electric Company (PG&E) is a public utility supplying electric and natural gas
service throughout most of northern and central California. Our service territory covers 70,000
square miles with a population of about. 13 million. In 1995, PG&E's utility assets were,
approximately $26.9 billion and operating revenues were $9.6 billion. PG&E has about 22,000
employees and operates more than 1,500 facilities subject to environmental regulations.
PG&E's electricity production comes primarily from seven natural gas-fueled power plants, two
nuclear units, 70 hydroelectric powerhouses, and a geothermal energy complex. PG&E also
purchases power from a wide array of resources, including hydroelectric, wind, solar, biomass,
and cogeneration. In 1995, its natural gas supply came primarily from Canada (64%) and the
* southwestern US (28%), with the remainder from California fields.
Drivers for Implementing an EMS
For many years, PG&E has had an EMS which is now in a fairly mature state. Our participation
in the EMS Demonstration Project was driven primarily by a desire to benchmark our existing
EMS against the developing ISO 14001 Standard arid against the systems employed by other
participants in the project. Our goal was to use the EMS Demonstration Project to identify areas
for potential EMS improvements. PG&E's participation had the additional benefit of providing a
realistic assessment of what would be required to achieve ISO 14001 certification, should a
business need for certification, develop. While PG&E does not market its products or services in
international markets, many of our customers do. Thus, ISO 14001 certification may provide a
competitive advantage in a California energy market that is rapidly approaching deregulation.
Self-Assessment
The electric and natural gas services we provide to our customers cannot be associated with
specific production facilities. Even the routes of transmission can vary, as loads within our
distribution system change. We determined, therefore, that our self-assessment should cover the
EMS for the entire company and include all aspects of production and distribution. The self-
assessment was conducted by senior managers in the environmental and law departments.
Because many of the ISO 14001 requirements were already covered by the existing EMS, the
principal focus of the self-assessment was on the effectiveness of EMS implementation
throughout the company;
i'
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Implementation
Based on the self-assessment results, we created a prioritized action plan for desired EMS
improvements. In developing the action plan, we recognized that some EMS improvements
would have existing environmental or business justifications, while others would not proceed
without a business decision to seek ISO 14001 certification.
PG&E has always enjoyed strong senior management support for its EMS, particularly as it
facilitates cost-effective compliance with environmental laws. Over the years, PG&E has
undertaken extensive education efforts with its employees to underscore the need for continual
improvement in environmental practices. This education effort helped to dispel the perception
that, since some past practices were adequate in protecting the environment, there was no reason
to change or improve these practices.
Challenges ,
We foresee two major challenges to achieving ISO 14001 certification. The first is that the
Standard's strong emphasis on documentation runs counter to an ingrained corporate bias to
minimize paperwork. Given that current environmental regulations already mandate extensive
recordkeeping requirements, establishing new voluntary documentation requirements may be a
hard sell, particularly if existing practices have functioned adequately to protect the environment.
As regulatory agencies themselves are moving to reduce mandatory paperwork, why levy new
documentation and recordkeeping requirements through a voluntary EMS standard?
.The second challenge will be common to most utilities. Under ISO 9000, certification has
pertained primarily to individual production facilities, not entire companies. Because we cannot
tell a customer the exact source of the electrons or gas molecules we provide, certification of
individual facilities to ISO 14001 is meaningless. However, if we must certify all (or even most)
of our 1,500 facilities, the costs and administrative burden of certification would be
unacceptable. PG&E will work with the appropriate accreditation organizations in an attempt to
find an acceptable certification process for the utility industry. •
Benefits
Our EMS has helped the company to ensure compliance and to reduce costs. Our audit function
feeds the continuous improvement cycle. We have seen cost reductions as a result of reduced
hazardous waste generation, improved management of hazardous waste recycling and disposal,
and rapid deployment of new, cost-effective compliance approaches. In addition, the EMS has
helped PG&E to reduce environmental impacts in other areas (including reductions in impacts on
fish and wildlife and reductions in air pollution). -
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Final Thoughts , .
PG&E believes that its participation in the EMS Demonstration Project supported our corporate
policy to continuously improve our EMS. Our participation also helped to position us for
eventual ISO 14001 certification, if such certification is deemed a valid business need.
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Pitney Bowes Inc.
Background v
Pitney Bowes is a leading provider of mailing, messaging and document handling products and
services with 30,000 employees in over 100 countries around the world. Pitney Bowes has two
primary manufacturing facilities, one located in Stamford, Connecticut and the other in Harlow,
United Kingdom. The company's .core business consists of mailing products and systems,
complemented by the additional product lines of facsimile systems, copier systems, financial
services and management services. Pitney Bowes Inc., headquartered in Stamford, Connecticut,
registered annual revenues in 1995 of over $3.5 billion* an increase of 9% over the previous year.
Drivers for Implementing an EMS
The impetus to implement an EMS and to attain certification to ISO 14001 originated in the
company's Corporate Safety and Environmental Affairs Department. EMS implementation was
viewed as a means to improve upon and integrate, existing environmental programs. Certification
to ISO 14001 was viewed as a means of attaining competitive advantage and ensuring long-term
security in the marketplace. EMS implementation also provides a vehicle to demonstrate the
company's environmental commitment to customers, investors and other stakeholders.
The Harlow, UK manufacturing site was chosen to be the subject of the EMS Demonstration
Project. The Harlow site is a medium- to large-sized manufacturing plant with approximately
900 employees. The site manufactures products for sale worldwide, but primarily in Europe and
the Far East. Primary manufacturing processes include metal finishing, machining, plastic
i injection molding, product assembly, and product refurbishment. The site has a history of
management system implementation, having attained certification to both BS 5750 and ISO 9002
several years earlier. In fact, this pre-existing ISO culture was one reason that the site was
chosen for the pilot.. Furthermore, predictions have been made (based on the company's ISO
9000 experience) that any marketplace effects of ISO 14001 would likely be felt first in Europe.
Self-Assessment .
The first step in the EMS implementation process was to perform a self-assessment using the
NSF self-assessment tool. The assessment was performed at the Harlow site by a group of
middle managers. After each manager completed the self-assessment checklist individually * all
of their responses were pooled and the response most frequently cited was chosen. The results of
this self-assessment indicated that the site was at the beginning stages for most of the elements of
ISO 14001—most of the elements were rated as either "no action taken" or "action initiated."
The self-assessment team did not rate the site as "complete" or "evaluated and sustained" for any
of the elements of ISO 14001. This self-assessment provided a good starting point from which
the Harlow site could plan itsVimplementation activities. It also required all of the managers
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involved in the self-assessment process to think about how each element of ISO 14001 related to
their organization. ' ' • '
Implementation
In April 1996, after five months of implementation activity, the self-assessment process was
repeated. This time the results showed encouraging progress. Several ISO 14001 elements had by
now earned a "complete" ranking, although none had yet become "evaluated and sustained/'
When the second self-assessment was conducted, only one element remained in the "no action"
category. Clearly, the site had made significant progress toward full EMS implementation in
only a few months.
At the time of this writing (August 1996), the Harlow site is preparing for the ISO 14001
registrar's pre-assessment visit, scheduled for September. Most elements of the Standard have
been fully implemented. The site has developed a detailed register of its environmental aspects,
a register of applicable laws and regulations, and an EMS Manual consisting of several
procedures, including those for EMS auditing, management review and emergency response. A
team of individuals on-site has been trained to perform internal audits and the first of these audits
has been scheduled. A process for ranking the significance of each environmental aspect has
been established and applied. In addition, environmental objectives and targets have been set, ,
based on the outcome of the process for ranking significance aspects and on the company's
environmental policy. Elements of the ISO 14001 Standard which remain to be fully. .
implemented include employee awareness training and external communication plans.
When the pilot was initiated, Pitney Bowes decided to keep the ISO 14001 initiative separate
from the site's existing ISO 9000 system. Since that,time, however, some small-scale integration
of these systems has occurred. The EMS Manual is formatted hi the same manner as the ISO
9000 manual, allowing for easier integration in the future should the company choose to do so.
In addition, approximately one-half of the individuals trained to perform internal EMS audits are
also responsible for internal ISO 9000 audits.
Challenges .
Challenges to implementation have been surprisingly limited. Senior management has been very
supportive of the pilot project and has allocated sufficient resources to ensure its success.
Despite some issues with individual staffing constraints, most members of the EMS team at the
site have been productive contributors. •
In retrospect, the biggest challenge to implementation has been interpretation of the Standard
itself. In particular the most difficult section of the Standard to interpret was section 4.3 rl
("Environmental aspects"). The choice of wording and lack of practical guidance made this
section difficult both to understand and to apply. In fact, a large portion of the person-hours
consumed to date on the project have been focused in this area. Even though the register of
environmental aspects has been completed for. the Harlow site, modifications to this register
continue to be made on a regular basis.
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Final Thoughts
Participation in the EMS Demonstration Project has been a rewarding experience for Pitney
Bowes. The project provided a much needed structure for implementation activities. In less than
one year from its EMS kick-off meeting, the Harlow site is ready for a certification assessment.
We believe that having a structured, certified EMS in place will improve our environmental
performance and add real value to the business.
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TRINOVA Corporation
Background
TRINOVA Corporation, headquartered in Maumee, Ohio, is a worldwide industrial manufacturer
and distributor of engineered components and systems. TRINOVA's companies, Aeroquip and
Vickers, operate approximately 75 facilities in 18 countries. The pilot facility chosen for the
EMS Demonstration Project has an excellent environmental compliance record, is ISO 9001
certified, employs 125 people, and manufactures hydraulic fittings for the aerospace industry.
Drivers for Implementing an EMS
TRINOVA did not join the EMS Demonstration Project based on any internal driver to
implement ISO 14001. Rather, the possibility that this voluntary Standard might become a de
facto requirement of doing business internationally created a heed to learn as much as possible
about ISO 14001, so that an implementation strategy could be developed. In short, our
motivation to learn about the ISO 14001 Standard and be prepared with an implementation
strategy was business driven. ,
Self-Assessment .
An assessment of the site's environmental management practices against the requirements of ISO
14001 was conducted by the pilot facility's environmental manager and an engineer from
corporate headquarters who had recently performed a comprehensive compliance review at the
facility. These two individuals then discussed and resolved any differences in their findings and
jointly produced a draft assessment report. The draft report was critiqued by an independent
EMS consultant before being finalized and submitted for the EMS Demonstration Project. This
outside critique ensured that the assessment provided an accurate basis upon which to move
forward. The critique also improved our understanding of the ISO 14001 Standard at an early
stage of the project. .
Implementation
Although a basic action plan was formulated to address gaps in environmental management
practices (as identified in the self-assessment), there was uncertainty as to how to reach full EMS
implementation. Because of the sheer number of detailed requirements in ISO 14001, the task of
fully implementing its requirements seemed daunting. One doesn't simply pick up and read ISO
14001 and then immediately begin to implement it. A great deal of time was required to review
the Standard and attend Demonstration Project meetings to build understanding and confidence
before resources were invested in EMS implementation.
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Implementation progress was limited at first because our approach was to focus on the 17
elements of the ISO 14001 Standard one at a time rather than on the Standard as a whole. We
believed that "environmental aspects" was an element that needed to be expertly fashioned and
installed before moving on to "legal and other requirements," which also needed to be expertly
fashioned and installed before moving on to "objectives and targets," and so on. A key to
improving our implementation progress was the realization that systems in place for compliance
with US environmental regulations would fulfill most ISO 14001 requirements (as noted by an
EMS Demonstration Project guest speaker who was one of the leaders of the US Technical
Advisory Group). -,.•.'
Based on this understanding, we began to incorporate elements of our pilot facility's existing
compliance program and procedures into the framework established for implementing ISO
14001. the initial EMS thus developed, though unrefined, can be improved over time,
consistent with the need to demonstrate Continual improvement in environmental performance.
Using this approach, we have made much better progress toward complete implementation of
ISO 14001 at the pilot facility. As a company that lacked a mature EMS at the outset of the EMS
Demonstration Project, TRINOVA is hardly in a position to offer advice to others on deeper
understanding of the fine points of ISO 14001; however, we would recommend this approach to
other companies mat experience difficulty in initially implementing their EMS.
A key element of our strategy during the Demonstration Project was to promptly form an
interdisciplinary team to identify environmental aspects, establish one or two targets related to
these aspects, and then carry out a program to achieve these targets. It was felt that some early,
tangible results would allow EMS development to be viewed as a dynamic and practical process,
rather than a paperwork / procedures exercise. The team felt strongly that demonstrating early
results would enhance the EMS Demonstration Project's acceptance and momentum at the
facility.
This strategy proved to be effective. People get excited when they have a feeling of
accomplishment in lessening the environmental impact of their jobs on the community in which
they live. Due largely to this approach in the earlier stages of the project, development of various
written procedures required by ISO 14001 (the more tedious part of implementation) has
proceeded in earnest and a positive attitude has been maintained.
One of the key challenges in implementing ISO 14001 is the Standard's great emphasis on
written procedures. More detailed documentation requires greater maintenance. While it is clear
that any system must be documented to be worthwhile, it does not follow that the greater the
level of documentation, the greater the value that will be added.
Benefits
The "ISO 14001 team" was comprised of the pilot facility manager, the environmental manager,
key workers from various areas within the facility, and a corporate representative. The team-
found that people on the manufacturing floor who actually work with processes which impact the
environment have a very thorough knowledge of those processes, while environmental managers
at the facility and corporate level had the most thorough knowledge of existing and emerging
, . ' • .'• •' '.•'.' 93 . ' • • •'••' - • ' .'-.
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regulations. It was demonstrated during the project that the EMS can bring these people closer
together. As employees' roles become better defined, and as information flow between
employees improves, they become better informed and proceed to more effectively, fulfill their
roles in managing environmental activities. A broad-based, improved understanding of
operations, coupled with the systematic approach described by ISO 14001, supports
environmental improvements. .
In addition, based on the systematic approach and the use of interdisciplinary teams, the pollution
prevention projects which were identified and implemented at the pilot facility, have reduced the
site's direct costs. Other pollution prevention projects should help the site to avoid certain costs
in the future. .
Final Thoughts
Our experience with the EMS Demonstration Project has shown that a systematic approach to
environmental management makes sense; however, we are somewhat skeptical at this time about
the potential benefits of ISO 14000 registration due to our experience with ISO 9000. ISO 9000
registration at the pilot facility has not resulted in the domestic or international trade
opportunities predicted in the earlier days of that Standard. Little value has been added to offset
the costs of maintaining ISO 9000 registration. Based on this experience with ISO 9000, our
current environmental strategy calls for implementing a systematic approach to environmental
management, but not for seeking ISO 14001 registration unless a business advantage can be
demonstrated. • . '
The EMS produced and the experience gained as a result of the EMS Demonstration Project will
serve as guides for TRINOVA's business units in which ISO 14001 registration is deemed to be a
prudent business decision. .
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United States Postal Service
Background
The United States.Postal Service (USPS) is a government-owned corporation whose mission is to
provide prompt, reliable, and efficient mail service to all .communities in the United States. With
over 720,000 employees working at more than 40,000 post office facilities nationwide, the USPS
is second only to the Department of Defense in terms of the size and reach of its operations and
activities. The USPS is organized into 10 area offices, which are further subdivided into 85
districts.
.Although one might not immediately associate the USPS with potentially significant
environmental impacts, a number of environmental issues relate directly to the USPS's core
business processes. These environmental issues derive from, among other things:
• the 205,000 vehicles the USPS operates and maintains;
• the chemicals it uses to maintain automation and mechanization;,
• the solid wastes it generates; and,
• the content of the products it sells. (For example, in manufacturing and selling postage
stamps, the USPS is the largest single consumer of adhesives in the United States.)
Drivers for Implementing an EMS
During the two years immediately preceding the EMS Demonstration Project, the USPS
undertook an intensive effort to improve the management and performance of its environmental
program. This effort included the development and issuance of a comprehensive environmental
policy statement; conduct of a thorough environmental effects (impacts) analysis of major
operations and activities; subsequent development of environmental strategies, development of
objectives and targets; and preparation of over 100 tactical action plans designed to implement
the strategy. Senior managers from the 10 area offices and major divisions within the
Headquarters actively participated in this effort. The principal focus of this effort was to:
• ensure compliance with environmental laws; ,
• integrate environmental considerations into business planning;
• promote individual responsibility for environmental protection and enhancement;
• work more closely with customers to address their concerns;
• track progress in meeting environmental goals and objectives; and
• set environmental standards for suppliers.
While this undertaking was, and continues to be immensely successful, senior management
recognized that a key element was still missing — the basic framework for a comprehensive
EMS. While not necessarily intending to pursue formal ISO 14001 registration, the USPS felt
that the requirements set forth in the ISO 140Q1 Standard described activities that any
' ' -• ""''•• • "•-.-•''.' 95 -,••'..•.' ' . •
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environmentally responsible organization should be doing as part of its routine business practice.
From that perspective, the USPS was eager to see just how well its program "measured up,"
while at the same time identifying areas where more emphasis was needed.
Recognizing that there was a great deal to learn about what an EMS is and what is required to
successfully develop and implement one, the USPS decided that active participation in the EMS
Demonstration Project would provide valuable insight and practical experience. Accordingly,
the USPS decided to participate in the project with the assistance of a private, non-profit third-
party organization (the Logistics Management Institute (LMI)), a federally-funded research and
development center located in McLean, Virginia.
Self-Assessment
LML staff members (who were relative newcomers to the EMS concept) underwent NSF
International's extensive EMS training program and conducted assessments at representative
USPS facilities. Facilities selected for assessment were the USPS Headquarters located in ,
Washington, DC, and the Southwest Area (SWA) Office, located in Dallas, Texas. Initial
assessments were completed in April and May 1995, with follow-up assessments, conducted in
the spring of 1996.
The assessments, which were conducted by LMI staff using the NSF self-assessment tool,
included face-to-face interviews as well as extensive documentation reviews. .Selected field
facilities (such as the Dallas Bulk Mail Center) were also visited so that assessors could
determine the degree to which policies and procedures were actually being implemented. At the
USPS Headquarters, interviews were conducted with key members of the Environmental
Management Policy Office, while at the SWA Office, the area environmental compliance
coordinator was the principal contact. The results of the initial self-assessment showed that the
SWA Office was roughly at a 25% implementation level. The Headquarters Office was found to
be at 49% implementation level because title extensive strategic planning initiative and other
actions were already underway at that location.
Implementation
Based on the self-assessment results, the USPS was particularly encouraged to note that many of
the requirements of ISO 14001 were already being addressed to some degree. (In fact, almost any
organization with a formal environmental program already has many elements of an EMS in
place.) The principal reason for the disparity in EMS implementation between the two pilot
locations of USPS organization was the fact that seven key district environmental coordinator
positions in the SWA were unfilled, and the single area coordinator was totally engulfed in
managing day-to-day operations. This left little time for the SWA organization to focus on EMS
implementation activities. Nevertheless, significant improvements were noted at both levels
during the reassessment one year later. The Headquarters Office improved to 87%
implementation, while the SWA Office achieved 51 % implementation — almost a 100%
improvement at both organizational levels.
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EMS areas where the USPS was found to have particular strength (or to have made the most
improvement over the year) included environmental policy, objectives and targets, resources
(especially environmental staffing), training and awareness, documentation, compliance auditing,
communications, and management review. Key areas that required additional emphasis included
development of performance indicators, impact and risk analysis at the area level, records
management, and EMS auditing.
Benefits
While the USPS has not made a final decision regarding formal ISO 14001 registration, it does
recognize that there are many tangible benefits from implementing a formal EMS. An EMS
establishes a basic framework for a sound environmental program and. subsequent environmental
performance. This in turn should serve to improve the overall condition of the environment by
reducing or eliminating negative impacts. An EMS should also result in more effective
compliance management, by ensuring that field operations are properly identifying and
addressing environmental concerns, allocating resources wisely, coordinating activities with
other key program offices, and reviewing and improving internal processes and procedures.
In addition, there are other compelling reasons for EMS implementation, such as:
• potential customers may require it (especially in the international marketplace);
• facility neighbors may want it (public image enhancement); and, ;
• it may affect relations with regulators and future liabilities (e.g., facilitate permitting, reduce
frequency and depth of inspections, and reduce severity of fines and penalties assessed).
In view of these considerations, the USPS will require the nine remaining area offices to
complete initial EMS self-assessments during 1997. This assessment will give the area
environmental coordinators an indication of where their strengths and weaknesses are, and how
much work needs to be done to meet .the requirements for a successful environmental program.
Hesuits of those EMS assessments will be input into the newly-developed Environmental
Management Information System designed to facilitate high level corporate management review
and tracking. Periodic reassessment results will be used to monitor progress across the USPS as
each area strives to meet all requirements of the ISO 14001 Standard. .
Final Thoughts
As with any company, large or small, the USPS knows that the future will likely bring increasing
environmental challenges and opportunities. By meeting those challenges and opportunities
head-on, the USPS will continue to ensure a safe and healthy environment, present a positive
public image as a high performance organization, reduce overall operating costs, and increase
business opportunities. Establishment of an EMS will provide an essential tool for continuous
refinement and improvement of its program performance, and will ensure the ultimate realization
of corporate environmental policy, goals and. objectives. • :
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Washtenaw County Government
Background
Washtenaw County's involvement in the EMS Demonstration Project is unique because it was
the only government agency involved. The Sheriff Department was chosen a& the pilot facility to
participate in the Demonstration Project on behalf of Washtenaw County. This department had a,
management staff that was committed to the goals of the project and was experienced with the
implementation of quality management principles. In addition, this department had a clear
command structure that designated responsibility and accountability.
Once the Sheriff Department was established as the facility to participate in the project, the
Director and Senior Environmental Manager from the Department of Environment and
Infrastructure Services met with a Commander in the ;Sheriff Department to brainstorm concepts
for an EMS and the benefits of having an EMS in place.
The Senior Environmental Manager and the Commander discussed specific issues that would
facilitate a feasible and effective EMS plan. These conversations focused on the differences
between EMS implementation in a private company and a public agency, and how an EMS
would fit into the Sheriff Department's command structure. A policy was created as a result of
these meetings. The policy is based on the development and maintenance of a quality
management system (QMS) which will include the EMS. The two systems will be integrated
because the department decided that both a QMS and EMS were necessary. This system Will be
implemented based on a holistic set of criteria, including the ISO 14001 Standard as well as
Criminal Justice policies, Corrections Operations policies, and additional standards. This will
ensure that these different standards will not be applied in a piecemeal fashion.
Drivers for Implementing an EMS
The service delivery sector of Washtenaw County is comprised of several departments, and
policies exist to govern these operations. The County is confronted with a need to manage these
areas by utilizing a well-developed, systematic approach to management. ,
In Washtenaw County, the current county-wide environmental policies concern waste
management (primarily recycling), purchasing of hazardous substances, and pollution prevention.
Although specific policies exist in these areas, there is a need for environmental policies that are
linked to a managerial approach. Several policies are currently at the planning stage; these
polices relate to sustainable development, economic development that will decrease urban
sprawl, and both quality arid environmental management systems.
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Expected benefits of an EMS include increased government accountability, and the opportunity
to lead by example. \ /
Self-Assessment ,
• • ' • , * •" ' • H • ' ' !
The Sheriff Department conducted a preliminary and final self-assessment. The assessments
focused on the Jail Operations and Food Services. These services comprise two of the,six
sectors within the Corrections Division. They were selected because they involved a high level
of material use, and staff were already documenting some of the material use streams. There
was a need to develop and implement a more advanced method for solid waste management to
replace current operational procedures. The measurables of concern were food service
packaging waste materials, dry cell batteries, and ammunition shell casings.
Once these measurables were identified and documented, they were presented to the staff
working in these areas. The staff agreed that a more effective approach for measurement and
accountability would enhance the quality of their work. A department-wide "Quality Team"
was formed to assist with the coordination of QMS/EMS policy initiatives. This diverse group
is comprised of representatives from various sectors of the department, including officers,
counselors, sergeants from Security Detail and Inmate Interactions Detail, and other divisions.
\ • ' , • " • . . •
The Sheriff Department self-assessment identified existing procedures, resulting in a viable
foundation to implement an EMS to target the measurables listed above. For the food service
packaging waste materials, Food Service staff was already required to count lids and cardboard
for safety purposes. For dry cell batteries, the department currently has a "gate keeper" system
for collecting old batteries and distributing new batteries. This system includes a central
operating station which is operated by one individual. Batteries are used extensively within the
department because they are necessary for flashlights, cellular phones, pagers and other
communication devices, hand held radios, and emergency response equipment. Dead batteries
accumulate and require proper disposal.
The brass ammunition shell casings are captured and recycled at the County practice target
range. An incentive exists to recycle these because the department returns the casings to the
ammunition suppliers for rebates on new ammunition. Although these initiatives currently
exist with little documentation and little management oversight, it is'hoped that the EMS will
improve and formalize the recycling efforts.
Challenges
• . • , • • i ,'.'''"". : •
In the. public sector, political influence establishes policy direction arid determines how
resources are utilized. Most private companies have a management component that determines
resource distribution; this allows flexibility in developing and adopting management schemes
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to attract customers. Government agencies, on the other hand, are faced with incorporating
policies that are developed at the top level based on public needs. These policies are then ,.
disseminated to the departmental level. The County is faced with the challenge of
incorporating an effective EMS within an atmosphere of elected officials and political agendas
that predetermine budgets and resource allocation.
Implementation
Implementation is now underway. The Senior Environmental Manager is developing the forms
that will provide precise documentation for accountability within the facilities. The department is
also identifying persons who will be responsible for adopting additional duties, or adjusting
current duties, that will facilitate the implementation of procedures. Once these areas are
developed into a working routine for the targeted facility, a management policy review or
auditing process will follow. A review process will have two purposes: 1) to identify procedures
that are not effective; and 2) to continue or enhance the development of areas that are achieving
the goals of the EMS. '
Once an EMS is documented and achieved, then the approach can serve as an example to be
applied to the additional four segments of the Corrections Division. This effort will also
eventually be applied to a county-wide EMS implementation program.
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. BIBLIOGRAPHY
. Cascio, Joseph, editor. The ISO 14000 Handbook. CEEM Information Services with ASQC
Quality Press, 1996.
Diamond, Craig P., "Voluntary Environmental Management System Standards: Case Studies in
Implementation." Total Quality Environmental Management, (Winter 1995/1996), pp. 9-23.
International Organization for Standardization, ISO 14001 : Environmental Management Systems
- Specification with Guidance for Use. 1996.
NSF International, Environmental Management Systems: An Implementation Guide for Small
and Medium-Sized Organizations. November 1996.
' '-"-'- V '"'""' * ,.
Tibor, Tom with Ira Feldman, ISO 14000: A Guide to the New Environmental Management
Standards, Irwin Professional Publishing, 1996.
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IX. APPENDICES
Appendix A
Background on ISO 14000, EMS Standards, and Registration
The Development of ISO 14000
The International Organization for Standardization (ISO) is responsible for the development
of the ISO 14000 series of international environmental management standards. ISO was
founded in 1946 and its headquarters,is located in Geneva, Switzerland. ISO has developed
international voluntary consensus standards for manufacturing, communication, trade, and
management systems. Its mission,is to promote international trade by harmonizing international
standards. Over 100 countries have national standards bodies that are members of ISO. The
American National Standards Institute (ANSI) is the U.S. representative to ISO.'
In June 1991, ISO created the Strategic Advisory Group on the Environment (SAGE). SAGE
assessed the need for international environmental management standards and recommended that
ISO move forward with their development. In January 1993, ISO created Technical Committee
207 (TC 207) which is charged with the development of the ISO 14000 series of standards. TC
207 is comprised of various subcommittees and working groups. Representatives from the ISO
member countries contribute their input to TC 207 through national delegations.
Li the United States, the U.S. Technical Advisory Group (U.S. TAG) develops the U.S.
position on the various ISO 14000 standards. The U.S. TAG is comprised of approximately 500
members representing industry, government, not-for-profit organizations, standards
organizations, environmental groups, and other interested stakeholders. The U.S. TAG has the
largest number of members of ISO member delegations. There are several organizations
involved in the administration Of the U.S. TAG's input to TC 207, including: ANSI; the
American Society for Quality Control (ASQC); the American Society of Testing and Materials
(ASTM); and NSF International. .' ,
TG 207 developed the ISO 14001 Standard which specifies requirements for an environmental
management system (the ISO 14001 Standard is the only standard in the ISO 14000 series which
is designed to be audited — such a document is called a specification standard). ISO 14001 ,<
contains 17 elements that comprise an EMS. In addition to ISO 14001, several guidance
documents are also being developed by TC 207. ISO 14001, ISO 14004 (an EMS guidance
document), and three environmental auditing guidelines (ISO 14010, ISO 14011, and ISO
140012), were published in September 1996. Other documents in the areas of environmental
labeling, life-cycle assessment, and environmental performance evaluation are under -
development. Published ISO standards must be reviewed and revised every five years.
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The Emergence of EMS Standards
Numerous factors have contributed to the emergence of EMS standards. The following is a brief
overview of some of the major factors. •
ISO 9000
The ISO 9000 series of international quality management standards was published in 1987. The
standards were created to promote consistent quality practices and to facilitate international trade.
The ISO 9000 series of standards has been adopted by more than 80 countries and is used as a
benchmark for quality management by industry and government bodies worldwide. In some
cases, ISO 9000 registration has become a prerequisite for doing business domestically and
internationally. In North America, over 13,000 companies are registered to ISO 9000.
The quality management system framework can serve as a foundation for environmental
management systems. In essence, an EMS is the application of quality management system
principles to the management of environmental affairs. While the ISO 9000 and ISO 14001
standards have different focuses, they share many similar requirements. The three specification
documents for ISO 9000 series are ISO 9001, ISO 9002, and ISO 9003. The key difference
between ISO 9000 and ISO 14001 is that ISO 14001 requires-planning steps to identify
environmental aspects and significant environmental 1 impacts which become the basis of
continual improvement.
Sustainable Development
In 1987, the World Commission on Environment and Development (Brundtland Commission)
coined the term "sustainable development" in its report entitled Our Common Future. This
report emphasized the need to balance environmental protection and economic growth.
In 1991, the International Chamber of Commerce (ICC) created the Business Charter for
^Sustainable Development. The ICC Charter is comprised of sixteen Principles for
environmental management that foster sustainable development. The Principles in this document
include some of the basic elements of environmental management systems.
In 1992, the United Nations Conference on Environment and Development (UNCED) was held
in Rio de Janeiro. The conference, also called the Earth Summit (or Rio Summit), resulted in
two noteworthy documents — Agenda 21 and the Rio Declaration. Agenda 21 is a
comprehensive guidance document for sustainable development, while the Rio Declaration is a
set of 27 principles for achieving sustainable development.
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These international initiatives on sustainable development marked the dawning of a new age in
environmental protection. The business community worldwide was asked to consider its impact
on the environment and to take steps to mitigate that impact.
Private Sector Programs & Public Concern for the Environment
Private sector programs, such as the Chemical Manufacturers Association's Responsible Gare*
program, the Global Environmental Management Initiative (GEMI), and the Coalition for
Environmentally Responsible Economies (CERES) Principles (formerly the Valdez Principles),
resulted in model codes of conduct that encourage environmental stewardship. Li addition,
public concern for the environment has provided strong motivation for the development of EMS
standards.
National EMS Standards & EMAS
In 1992, the British Standards Institute (B SI) published BS 7750, the first national standard for
environmental management systems. BSI had previously published BS 5750 (a quality
management system standard in the United Kingdom) which was a significant contribution to the
development of ISO 9000. ISO 14001 was largely based on BS 7750, and the two standards
share many similar requirements. The BS 7750 Standard, however, is viewed by many to be
more stringent than ISO 14001. For example, BS 7750 requires that an organization compile a
register of its significant environmental effects, and a register of all legislative, regulatory, and
other policy requirements. In addition, BS 7750 requires an organization to make its
environmental objectives publicly available.
Following the publication of the United Kingdom's BS 7750, a proliferation of national EMS
standards emerged, including standards from Ireland, France, South Africa, and Spain. These
various EMS standards did not all share the same requirements, and hi some cases the
requirements were contradictory. It became clear that in order to facilitate international trade,
there would have to be one international EMS standard that would be accepted around the globe.
In addition to the national EMS standards, European legislation was developed. The Eco- .
Management and Audit Scheme (EMAS) was adopted by the European- Union (EU) in 1993.
EM AS is a regulation that enables industries to voluntarily implement formal environmental
management systems in order to improve their environmental performance. While ISO 14001
and BS 7750 apply to organizations (or parts thereof), EMAS is restricted to site-specific
industrial activities. EMAS participants must prepare an environmental statement specific to
each site concerned and provide information to the public about their environmental aspects. '
Third-party verification of the EMS is an essential component of EMAS. Participating
organizations are included on the EU list of participating sites.
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The Registration Process
EMS registration is the process whereby a non-biased "third-party" attests that an organization's
EMS conforms with the requirements of an EMS standard, such as ISO 14001. It is important to
note that the ISO 14001 Standard does not require third-party registration, but market forces and
regulatory incentives may provide strong encouragement for registration. The third-party
organization that performs the registration services is called a "registrar." The type of
registration services that will be offered for ISO 14001 will be similar to those offered for the
ISO 9000 series of quality management system standards. In North America, over 13,000
companies have been registered to ISO 9000.
The ISO 14001 Standard does not require that an organization implement the EMS at the
corporate level. For example, one organization may choose to implement the Standard
throughout the entire organization, while another may implement the Standard in one particular
facility. Therefore, an organization can elect to register the entire organization, a division(s),
selected facilities, a particular facility, or selected operations within a facility. The key factor in
choosing the organizational unit for registration purposes is that it has its own functions and
administration.
A registrar can be "accredited" by a third-party accreditation body that is independent of the
registrar. Accreditation is the process by which a registrar's competence is evaluated by a third-
party accreditation body with national or governmental recognition. Accreditation greatly
enhances a registrar's credibility.
Registrars may have different registration processes and may offer different types of services.
The following description of the registration process is fairly typical of the process used by many
registrars. It is provided for illustrative purposes:
Step 1: Application for Registration
The organization that wishes to obtain EMS registration submits an application indicating the activities and
facilities of the organization or site to be registered.
Step 2: Review of EMS Documentation /Desk Audit
The organization submits documentation of its EMS, which includes its environmental policy and
documentation that indicates how it meets each clause in the ISO 14001 Standard. The documentation is
reviewed by a designated lead auditor. The auditor generates a written report which indicates confonnance
or nonconformance of the documented EMS to each clause of the Standard.
Step 3: On-site EMS Readiness Review
The lead auditor conducts an on-site visit in order to resolve any EMS documentation nonconformances
and to verify that the facility is prepared for a full registration audit. The on-site visit is also used to assess
the resources and logistics necessary for the full registration audit.
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Step 4: Registration Audit
An audit team will conduct an on-site audit to evaluate and verify through objective evidence (interviews,
procedures, records, etc.) that the EMS conforms to the requirements in the ISO 14001 Standard, is
effectively implemented, and has sufficient provisions to be maintained.
*/ Step 5: Registration Determination r
A final report containing the results of the registration audit is submitted to the organization. To receive a
Certificate of Registration, an organization must successfully meet the requirements of the ISO 14001
* Standard, as well as the registration policies of the registrar. _, ;
Step 6: Surveillance
Surveillance audits are typically performed semi-annually to verify continued conformance. During the
surveillance audits; the audit team may only audit certain elements of the EMS. Over a three year period,
however, all of the elements of the EMS must be reviewed to ensure continued conformance to the
requirements of the ISO 14001 Standard. ,
Registration Audit Results .
There are essentially three possible results from a registration or surveillance audit. The registrar can
determine that the applicant is: . : :
: 1) Recommended for registration , i
There are no major nonconformities;
2), Recommended for registration following verification of corrective action - . .' * > '
There are one or more major nonconformities which can be corrected and verified without a full
re-audit; or '•'. ' '
3) Recommended for an on-site reassessment _ ,
There are several major nonconformities which indicate a breakdown of .the EMS. Another full
on-site audit is required. . ,
Note: A major nonconformity is the absence or complete breakdown of an EMS element. A large number
of minor nonconformities for one element may be considered a major nonconformity. A minor
conconformity is a single observed nonconformity.
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Appendix B
Questions Asked of Project Participants at the Conclusion of the Project
What factors are motivating/driving your company to implement an EMS?
What have been the barriers/challenges to EMS implementation encountered thus far, and
how has your organization addressed them?
What specific requirements in ISO 14001 are questionable (i.e., unclear, of limited value,
or too difficult to implement) and why? Please provide a reference to the actual language
when answering this question.
Has (or will) implementing the EMS helped your organization develop more effective
approaches for managing environmental compliance activities?
Has implementing the EMS improved your organization's overall environmental
performance? Which specific environmental impacts have been affected?
Has implementing the EMS reduced overall environmental management costs? Which
costs in particular? •
Has implementation brought or maintained domestic or international trade opportunities?
If so, explain. • • •
In what ways have you integrated your EMS with ISO 9000 or other existing management
systems (e.g., health & safety)? Please explain.
Have you attempted to calculate the costs of EMS implementation? If so, how did you
define your implementation "starting point" (i.e., was this project the EMS starting point,
or some time before that)? What costs were considered in the calculation?
What other benefits have you received, or expect to receive, from EMS implementation?
What advice would you offer to regulators (federal, state) as they look for ways to use the
EMS approach and ISO 14001 in their interactions with the regulated community?
107
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Appendix C
Elements of the ISO 14001 Standard: A Snapshot
* ' ' . ' :\
Environmental policy - Develop a statement of the organization's commitment to the
envkonment. Use this policy as a framework for planning and action.
i -, ' ' • - ' l •,- i .
Environmental aspects - Identify environmental attributes of the organization's products,
activities, and services. Determine those that could have significant impacts on the environment.
Legal and other requirements - Identify and ensure access to relevant laws and regulations (and
other requirements to which the organization adheres).
Objectives arid targets - Establish environmental goals for the organization, in line with its
policy, environmental impacts, views of interested parties, and other factors.
Environmental management program - Plan actions to achieve objectives and targets.
' • ,'-•'-.'.• • > ' • '• • '
Structure and responsibility - Establish roles and responsibilities, and provide resources.
Training, awareness and competence - Ensure that employees are trained and capable of carrying
our then-environmental responsibilities. / ,
Communication - Establish processes for internal and external communications on environmental
management issues. .
EMS documentation - Maintain information on the EMS and related documents.
Document control - Ensure effective management of procedures and other system documents,
Operational control - identify, plan, and manage operations and activities in line with the
organization's policy, objectives, and targets.
Emergency preparedness and response - Identify potential emergencies and develop procedures
for preventing and responding to them.,
Monitoring and measurement - Monitor key activities and track environmental performance.
Nonconformdnce and corrective and preventive action - Identify and correct problems and
prevent recurrences. ,
Records - Keep adequate records of EMS performance.
EMS audit - Periodically verify that the EMS is functioning as intended.
'Management review - Periodically review the EMS with the goal of continual improvement.
108
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Appendix D
Excerpts from NSF's EMS Self-Assessment Tool
This appendix contains two items:
• the first page of the checklist from NSF's EMS Self-Assessment Tool; and
• descriptions of the five implementation levels used in the tool.
These excerpts from the assessment tool are provided here to illustrate the format of the EMS
self-assessments and independent assessments that were conducted as part of the EMS
Demonstration Project. The sample page taken from the checklist contains the exact language
from the ISO 14001 Standard. The actual checklist, which contains EMS requirements from the
entire Standard, is approximately nine pages in length.
As discussed in Section IV of the report, the checklist breaks down the 17 elements of ISO 14001
into 63 individual requirements. The sample page provided contains the first eight of these
requirements. The numbers that appear with each requirement are not found in the actual
Standard; they were developed solely for use in NSF's EMS Self-Assessment Tool.
109
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Appendix D
Checklist for ISO 14001: Sample Page
Requirement
M4.2 ENVIRONMENTAL POLICY
Implementation Level
Comments
H^^^^^HMHi^^^HiMI^^HHMil^HHIIHMMH^^^^^^^^HIHIII^^I^^^^^^^Ml^H^^H^n^^^^^^^^^HHH^H^HflH^H^HHMHBl
Top management shall define the organization's environmental policy and ensure that it
I 1
4.2.1 is appropriate to the nature, scale and
environmental impacts of its activities,
products or services;
DOOM
DBS
DNA
DIN
DPAR
4.2.2 includes a commitment to continual
improvement and prevention of pollution;
DOOM
DBS
DNA
DIN
DPAR
4.2.3 includes a commitment to comply with
relevant environmental legislation ana
regulations, and with other requirements to
which the organization subscribes;
DOOM
DES
DNA
DIN
DPAR
4.2.4 provides the framework for setting and
reviewing environmental objectives and
targets;
DOOM
DES
DNA
DIN
DPAR
4.2.5 is documented, implemented and
maintained and communicated to all
employees; and
DOOM
DE.S
DNA
DIN
DPAR
4.2.6 is available to the public.
DOOM
DES
PNA
DIN
DPAR
4.3.1 Environmental! Aspects
4.3.1.1 The organization shall establish and
maintain (a) procedure(s) to identify the
environmental aspects of its activities,
products or services that it can controljand
over which it can be expected to have an
influence, in order to determine those which
have or can have significant impacts on the
environment. ."''-,
DOOM
DES
DNA
DIN
DPAR
4.3.1.2 The organization shall ensure that
the aspects related .to these significant
impacts are considered in setting its
environmental objectives.
DOOM
DES
DNA
DIN
DPAR
11.0
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Appendix D
EMS Assessment Checklist
Implementation Level Descriptions
Described below are the five implementation levels used in NSF's EMS Self-Assessment Tool.
Achievement levels NA, IN, and PAR indicate that the requirement has not been met - this is
categorized as "NO" on the assessment checklist. Levels COM and ES indicate that the
requirement has been met - this is categorized as "YES" on the checklist.
No Action (NA) - No significant or formal actions have been taken by the organization to plan or
implement activities that would meet this requirement.
Initiation (IN) - The organization has begun to plan or undergo specific activities that would
contribute to fulfilling this requirement. Activities might include one or more of the following:
• general planning has begun or been assigned;
• a written action plan or outline is prepared, or being prepared;
• draft policies, procedures or initiatives are under development or review;
• responsibilities for specific planning or design activities have been assigned; or
• pilot activities to assist in the design process are underway.
Partial Implementation (PAR) - Implementation of an action plan has begun, but major gaps in
implementation exist in the organization. Specific activities that contribute to fulfillment of this
requirement Have been implemented in only parts of the organization; and/or some but not all of
the necessary activities have been implemented; and/or activities are fully deployed but are not
implemented effectively.
Complete Implementation (COM) - All specific activities necessary to fulfill this requirement
have been effectively implemented in all parts of the organization.
Evaluated & Sustained (ES) - Specific polices, procedures, or activities that contribute to
fulfillment of this requirement have been reviewed and evaluated, and improvements, where
appropriate, have been introduced. Activities have been documented, sustained over time (e.g.,
one full business cycle), and have been fully integrated into routine business operations.
Ill
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