Final Report
US EPA Region IX
Environmental Menegemnnt Systems end Financial Incentives
A Merit Partnership tor Pollutioo Prevention Project
Discussions	w
About Environmental Management
Project Manager:
Bonnie Barkett
(415) 744-1908
barkett.bonnie@epamai 1. epa. gov
September 1998
Prepared by EQQUA™ under
Order No. 8S-0131-NASX
ALattanner@eqqua.com


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Discussions with Industry
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Foreword
The Merit Partnership for Pollution Prevention (Merit) is a cooperative venture of
the public and private sectors. Merit, initiated by the Environmental Protection
Agency, Region IX, in 1993 includes major industry leaders, small and medium size
businesses, state and local government agencies, environmental organizations, and
community organizations. The mission of Merit is to develop and promote pollu-
tion prevention (P2) practices and technologies that both protect the environment
and contribute to economic growth. Merit has done this primarily by developing
and facilitating the implementation of pilot projects that demonstrate innovative
P2 practices and technologies. Merit projects vary widely in scope and in the in-
dustries involved, but one criterion that they have in common is a focus on the
dual goals of achieving improved environmental and economic performance as a
result of P2 practices and technologies. Merit projects often serve to inform EPA's
public policy discussions and Merit is actively involved in the development of the
agency's positions on Environmental Management Systems (EMSs).
Merit has been studying environmental management systems for almost three
years. What began as a mild interest in determining whether or not environmental
management systems could be a vehicle for pollution prevention technologies and
practices has turned into an endeavour that now has us exploring the broader po-
tential of environmental management systems as a public policy tool for improving
environmental performance and compliance and economic growth.
A major part of our effort to understand whether or not environmental manage-
ment systems can and do contribute to improved environmental performance and
economic growth has been the myriad discussions we have had with representa-
tives of small and large businesses in a variety of industries about environmental
management. This report is based on these discussions. The discussions focussed
on the real-life, hands-on experience of the people who actually manage environ-
mental impacts. This paper does not offer conclusive or comprehensive findings
about how environmental management systems affect environmental performance
and economic growth. It conjures up more questions than it answers. Neverthe-
less, we think the trends and issues analysed will be useful as both the public and
private sectors pursue our common goals of environmental protection and eco-
nomic growth.
The willingness of so many people in industry to speak openly and at length with us
has been critical to the development of this report and to our ongoing efforts to
explore the utility of environmental management systems. I am grateful to all of
the individuals in industry who took the time to speak with us about environmental
management. There are many other people who have contributed their knowl-
edge, expertise, and time to both this report on environmental management sys-
tems and to some of Merit's other EMS-related efforts. Alan Lattanner of EQ.QUA,
both as a volunteer and a consultant, has made an enormous contribution to this
project. I am very grateful for the contributions of Greg Barats, Richard Chinn,
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l/	(J
Ira Feldman, Suwanna Gauntlett, Scott Johnson, Charles McGlashan, David Mon-
sma, Donna Sandidge, James Schaarsmith, John Theiss, and Kathleen Thurmond.
^Dan Reich, the Merit Team Leader, has been a stalwart source of guidance and sup-
port during this project. Finally, I thank all of the members of the Merit Team -
vljaura Bloch, Arthur Haubenstock, Katherine Taylor, andVrfice Tobriner - for their
contributions to this work.
VBonnie Barkett
The Merit Partnership for Pollution Prevention
United States Environmental Protection Agency
San Francisco, California
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Table of Contents
FOREWORD	1
TABLE OF CONTENTS	3
INTRODUCTION	5
Purpose	5
Participant Selection	6
Companies participating in the EMS Discussions	7
Development of Topics for Discussion	7
Results Desired	8
ANALYSIS	9
Survey Population	9
Discussion Topics	10
Analysis of Findings	11
Policy, Systems and Standards	11
Audits, Compliance and Performance	13
Environmental Outreach	13
Motivation and Benefits	15
Conclusions	16
QUESTION BY QUESTION SUMMARY OF FINDINGS	17
1.	Does your company have an environmental policy?	17
2.	Does your company have an environmental management system?	18
3.	Do your company's environmental policy and management system conform
to any recognized standards?	20
4.	Does your company conduct compliance audits on a regular basis?	22
5.	Does your company conduct pollution prevention audits on a regular basis?
How frequently?	24
6.	Describe your method of determining your company's environmental aspects
and impacts?	26
7.	Describe your method of determining the relative significance of your
environmental aspects and impacts?	27
8.	Does your company measure its environmental performance or use
environmental performance indicators? Please describe.	29
9.	Does your company have a mechanism for community participation and/or
public information sharing about its environmental performance?	31
10.	Has your company's environmental management system improved your
company's environmental performance? Please describe.	32
11.	What are the key elements of your environmental management system that
most contribute to improved environmental performance?	34
12.	Are you encouraging or requiring your suppliers to implement
environmental management systems?	36
13.	Has operating under an environmental management system resulted in
economic benefits to your company? Please describe.	38
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14.	Are the economic benefits (identified in your comments on the previous
topic) associated with any particular element of your environmental
management system?	40
15.	What elements of an environmental management system are necessary to
assure compliance with environmental regulations?	42
16.	Has your company's environmental management system improved your
company's compliance with environmental regulations?	44
17.	Should environmental management systems be encouraged by regulatory
agencies?	46
18.	What factors did your company consider in your decision to adopt an
environmental management system?	47
19.	Did sustainable development concepts influence your decision to adopt an
environmental management system? Please describe.	50
20.	How are sustainable development concepts or values reflected in your ems,
if at all?	51
21.	Did regulatory compliance issues influence your decision to implement an
environmental management system?	52
22.	Are there internal or external barriers to implementing an environmental
management system, and what are they?	53
23.	What are the critical factors for successful implementation of an
environmental management system?	55
24.	Are there any specific financial drivers that influenced your decision to
adopt an environmental management system?	56
25.	Are there any specific environmental drivers that influenced your decision
to adopt an environmental management system?	57
26.	On a one-to-ten scale with ten being "expert" level, how familiar are you
with the ISO 14000 standards?	58
27.	What factors influence the decision to become registered to an
international standard tike ISO 14001?	59
28.	Does your company intend to become (or is it) registered to ISO 14001 or to
any other standard?	60
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Introduction
Purpose
The Merit Partnership for Pollution Pre-
vention (Merit) is exploring the potential
of Environmental Management Systems to
both improve environmental performance
and contribute to economic growth. Merit
is examining issues and questions such as:
>	Can an environmental management
system (EMS) improve environ-
mental performance and, if so,
what elements of an EMS are nec-
essary to that end.
>	Is pollution prevention (source re-
duction) utilized more by compa-
nies that implement environmental
management systems.
>	Are environmental management
systems economically sound for
small and medium size businesses.
>	Can the implementation of an EMS
result in economic benefits to a
company and, if so, are those eco-
nomic benefits the result of spe-
cific elements of the EMS.
>	What components of environ-
mental management systems are
necessary to assure compliance
with environmental laws.
>	Can an EMS improve a company's
compliance record and, if so,
should environmental management
systems be encouraged or man-
dated by regulatory agencies.
>	Can environmental management
systems form the basis for an al-
ternative regulatory path for "en-
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vironmentally excellent" compa-
nies.
> Should environmental management
systems be a cornerstone of public
policies designed to promote sus-
tainable development?
Merit is probing some of the issues men-
tioned above for the purpose of informing
the discussions about environmental man-
agement systems that are ongoing in both
the public and private sectors. Merit
plays an active role in the development of
EPA's positions regarding environmental
management systems. As a cooperative
effort of the public and private sectors,
Merit is uniquely suited to gather and
analyse information that may help to in-
form both public policy making and deci-
sion making in the business world. We
hope that this report is a step in that di-
rection.
Participant Selection
Participant selection was informal and
non-scientific. Companies that were
known to the Merit Partnership, either di-
rectly or through secondary contacts, to
have some kind of environmental man-
agement functions in place were invited
to participate. Companies that were
known generally to be environmental
leaders were invited to participate. Com-
panies that heard about our project and
asked to participate were welcomed into
the project.
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Companies participating in the EMS Discussions
AUergan, Inc.
Allied Signal Aerospace
Alta Plating and Chemical
Corporation
ARCO
Arizona Electric Power
Cooperative
Artistic Plating and
Metal Finishing, Inc.
Baxter International, Inc.
BHP World Minerals
Burr-Brown Corporation
Chevron Research and
Technology Company
Department of the Navy
General Electric Nuclear Energy
Hewlett-Packard Company
Homestake Mining Company

Integrated Device Technology
Lockheed Martin
LSI Logic Corporation
Motorola
Nike, Inc.
Occidental Petroleum Corporation
Pacific Gas 6t Electric Company
Patagonia
Quantum Corporation
Rohm and Haas Company
Skyway Freight Systems, Inc.
ST Microelectronics, Inc.
The Clorox Services Company
Thermatrix Inc.
United Paradyne
Varian Associates
A large number of the participants have
facilities based in the EPA, Region IX
states (California, Arizona, Nevada, Ha-
waii). Merit purposely did not have dis-
cussions with companies that are currently
involved in Merit EMS pilot projects.
Development of Topics for Discussion
The topics for discussion were developed
by the Merit Team with the assistance of
experts in the field of environmental
management. The topics for discussion
served as the starting points for the gath-
ering of information and data about the
companies' environmental management
practices and/or environmental manage-
ment systems. Alan Lattanner of EQ.QUA
conducted the initial discussions with in-
dustry upon which this report is based.
Many of the initial discussions were fol-
lowed by more in-depth and informal dis-
cussions between Merit and company rep-
resentatives.
Some of the major factors considered
during the development of the topics for
discussion are listed below.
> Is it a subject matter on which
more information is needed to
make public policy decisions.
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>	Is it a subject matter which will
shed light on the decision-making
of those in industry.
>	Does the subject matter inform the
body of knowledge about the
practicalities of environmental
management and EMS implementa-
tion.
>	Is it a subject matter about which
there is considerable confusion,
disagreement, debate or contro-
versy?
We tried to develop the topics and frame
the discussions in such a way as to both
collect specific and consistent data while
still having open exchanges and sharing of
information, experience, and ideas.
Results Desired
We hope that this report of our findings
will serve to inform and enliven the public
and private sector dialogues on the sub-
ject of environmental management and
environmental public policy. We also hope
that the discussion of our findings will in-
spire further cooperative efforts among
regulatory agencies, industry, and other
stakeholders in the area of environmental
management.
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Analysis
Key Point
Respondent company revenues
represent 6.28 percent of US
Gross National Product.
Table 1.
Industry Sectors Represented
by Responding Companies
Sector
Aerospace
Apparel
Chemicals
Contract Services
Electric Utility
Electronics
Fabricated Metal Products
Metal Mining
Military
Petroleum
Precision Instruments
Transportation Equipment
Survey Population
Approximately 80 companies were invited
by US EPA Region IX to participate in an
Environmental Management Systems
Roundtable to be held in San Francisco on
September 17, 1998. In preparation for
the Roundtable, those invited were asked
to voluntarily discuss the environmental
management practices of their company
with the Merit Partnership and/or a Merit
representative.
Thirty-one (31) companies, about 40 per-
cent of the invited population, elected to
participate in the discussions.
Industry representation of the participants
is shown on Table 1. The responding com-
panies represent a broad cross-section of
the US economy including manufacturing,
services, power utilities and the military.
The responding companies had combined
revenues of 435.32 billion dollars in their
most recently reported fiscal year (ex-
cluding the military and privately held
firms). Ten (10) of the firms are listed by
Fortune Magazine among the 100 US com-
panies with the largest revenues.
Respondent company revenues represent
6.28 percent of US Gross National Product
based on the 1994 GNP data, the most re-
cent available.
Job titles of the participants are shown in
Table 2. Respondents came primarily from
environmental, health and safety func-
tions, but also from executive manage-
ment, facility management and opera-
tions.
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Table 2. Job Titles of
	Participants	
Title
Chairman, President and CEO
Corporate Manager,
Compliance Assurance
Corporation Environmental
Specialist
Deputy Environmental
Business Line Manager
Director of Facilities 6t
Environmental Affairs
Director, Environmental
Affairs
Director, Waste Management
Program
Environmental Programs
Manager
Group Manager, Environ-
mental Services 6t Auditing
Manager, Corporate EH&S
Audits
Manager, Environment, Health
& Safety
Manager, Corporate
Environmental Affairs
Manager, Environmental
Services
Manager, External Affairs,
Corporate ES&H
Manager, Space Planning
Business Controls
Senior Environmental
Engineer
Strategic Environmental
Management Specialist
Team Leader, Health, Safety
& Environmental
Vice President
Vice President, EH&S
Discussion Topics
Both the private and public sectors have a
stake in the environmental and economic
costs of pollution and environmental deg-
radation. They share a common interest in
adding value to the US economy by pro-
moting sound environmental management.
The discussion topics were selected to
shed light on the potential use of envi-
ronmental management systems to im-
prove environmental performance and
economic growth.
The Merit Team developed twenty-eight
(28) discussion items that address nine (9)
topic areas (Table 3). The topics address
the manner in which modern organizations
manage the environmental aspects of
their business.
Table 3.
Topic Areas Addressed
Topic
- Policy
_ Systems
— Standards ^ > L(Ooi^ ?
C^Audits^>
Performance
Compliance
Outreach
Motivation
Benefits
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Analysis of Findings
This section first examines the total
population of participating companies in
terms of their environmental policies and
environmental management systems.
Then, having identified the subset of
companies that employ an environmental
management system, we focus on that
group to evaluate the influence of an EMS
on the topic areas listed in Table 3.
Policy, Systems and Standards
Ninety-seven percent of the respondent
total population of thirty-one companies
(hereafter "the respondents") have an
environmental policy that applies to the
organization as a whole.
Among the respondents that have an envi-
ronmental policy, eighty-four percent
have an environmental management sys-
tem. The remainder does not consider
their current approach to environmental
management to fit within their definition
of an environmental management system.
Seventy-seven percent of the environ-
mental management systems conform to a
recognized environmental standard (either
ISO 14000 or the European Eco-
Management and Audit Scheme "EMAS").
Fifty-four percent of the respondents that
have an environmental management sys-
tem intend to register to an international
standard or currently have one or more
registered facilities.
Respondents, both those that do and those
that do not have an operating environ-
mental management system in their com-
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Key Point
A significant percentage of re-
spondents conduct audits for
compliance with regulations and
for pollution prevention (85 per-
cent and 81 percent, respec-
tively).
pany, demonstrated a good understanding
of the term "environmental management
system."
Environmental management systems typi-
cally apply to an organization as a whole,
a business unit, or an entire facility. Re-
spondents stating that their organization
did not employ an environmental man-
agement system mentioned alternative
approaches to meeting environmental re-
sponsibilities. The most frequently men-
tioned alternative is to focus environ-
mental responsibility on a particular de-
partment (e.g. the EH&S or Environment,
Health and Safety department) whose job
it is to assure compliance and to improve
the organization's environmental perform-
ance. Respondents pointed out that it is
not necessary to have an EMS to have good
environmental performance. They also
identified specific benefits, discussed
later in this section that resulted from
implementing an EMS even though their
organization already had a good environ-
mental record.
Policy, Systems and Standards Summary
>	A high percentage (97 percent) of
respondents have both an envi-
ronmental policy and an environ-
mental management system in
their organization.
>	Over three-quarters of those envi-
ronmental management systems
conform to ISO 14000 (or EMAS).
>	Over half of the conforming re-
spondents intend to register, or are
already registered at one or more
facilities, to either ISO 14000 (or
EMAS).
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Table 4.
Percentage "Yes" Answers among
Respondents Using
Environmental Management
Question
Pet
Have a policy?
100%
Have an EMS?
100%
Conform to standard?
77%
Compliance audits?
85%
Conduct P2 audits?
81%
Use EPIs?
96%
Community outreach?
81%
Improved Performance?
92%
Encourage suppliers?
73%
Economic benefits?
62%
Specific source of eco-
65%
nomic benefits?

Improved compliance?
65%
Should agencies encour-
88%
age?

Sustainability driver?
73%
Compliance driver?
38%
Barriers to EMS?
65%
Financial drivers?
42%
Environmental drivers?
35%
Intend to register?
54%
The following sections focus on the popu-
lation that has already implemented an
environmental management system. To
distinguish this population we refer to it
as the "EMS respondents." Table 4 shows
the survey results adjusted to reflect the
responses of those that have an operating
EMS.
Audits, Compliance and Performance
Ninety-six percent of EMS respondents use
environmental performance indicators
("EPIs"). EPIs measure the effects of an
environmental management system.
A lesser yet still significant percentage of
EMS respondents conduct audits for com-
pliance with environmental regulations
and for pollution prevention (85 percent
and 81 percent, respectively).
Many EMS respondents said that they no
longer focus their environmental man-
agement control activities on compliance.
Instead, they have revised the audit proc-
ess to focus on the environmental man-
agement system.
In summary, nearly all EMS respondents
utilize environmental performance indica-
tors and over eighty percent conduct
audits for compliance with regulations and
for pollution prevention.
Environmental Outreach
The term "Environmental Outreach" re-
fers to an organization's policies in two
areas:
> Communications about envi-
ronmental aspects, impacts and
performance with communi-
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Key Points
Some EMS respondents have put
suppliers on notice that registra-
tion will be required to do busi-
ness within the next few years.
Some companies, including IBM
and ST Microelectronics, have
notified hundreds of their sup-
pliers that registration to a rec-
ognized standard will become an
important, or required, pur-
chasing criteria in the near fu-
ture.
Although only 42 percent of
companies using an environ-
mental management system were
motivated to adopt the EMS on
the basis of financial considera-
tions, 62 percent reported eco-
nomic advantages resulting from
implementing their EMS.
ties, other stakeholders, and
interested parties; and
> Interaction with suppliers and
customers about environmental
matters of mutual concern.
Eighty-one percent of EMS respondents
conduct some form of community or
stakeholder outreach. For many this takes
the form of a corporate environmental
report. Numerous respondents said that
their environmental policy and perform-
ance information is available via their
corporate Internet site.
Seventy-three percent said that they en-
courage suppliers to implement environ-
mental management systems. Some EMS
respondents have put suppliers on notice
that registration will be required to do
business within the next few years.
Given the economic power of the EMS re-
spondents as a group (see earlier "Survey
Population" section) a supplier registra-
tion requirement, even by a fraction of
the Fortune 100, could significantly accel-
erate the rate of EMS adoption in the US.
In fact, the survey did reveal evidence of
this trend. Some companies, including IBM
and ST Microelectronics, have notified
hundreds of their suppliers that registra-
tion to a recognized standard will become
an important, or required, purchasing cri-
terion in the near future.
Environmental Outreach Summary
Community and stakeholder outreach oc-
curs primarily through corporate annual
environmental reports and corporate
World Wide Web Sites.
Suppliers are being encouraged to adopt
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environmental management systems.
There is a clear indication that some ma-
jor companies will require registration (of
their suppliers) to an environmental man-
agement systems standard before the year
2000.
Key Point
As operating experience
grows and companies share
information about their posi-
tive financial, environmental
and marketing experiences, it
is likely that environmental
management systems will be
adopted by more and more
organizations.
Motivation and Benefits
Less than half of the EMS respondents said
that specific financial, environmental or
compliance issues influenced their deci-
sion to adopt an environmental manage-
ment system. The actual responses are
shown below (as percent "Yes" of total).
Driver
>	Financial?
>	Environmental?
>	Compliance?
Percent
42 percent
35 percent
38 percent
These are intriguing results when com-
pared to the percentage of EMS respon-
dents who say they have experienced eco-
nomic, environmental and compliance
benefits as a result of implementing an
environmental management system. Those
results are shown below.
Benefit
>	Economic?
>	Environmental
Performance
>	Compliance?
Percent
62 percent
92 percent
65 percent
Although only 42 percent were motivated
by financial considerations, 62 percent
reported economic advantages to imple-
menting an environmental management
system.
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Although only 35 percent were motivated
to improve environmental performance,
92 percent reported improved environ-
mental performance after implementing
an EMS.
Although only 38 percent were motivated
by a desire to improve compliance with
environmental regulations, 65 percent re-
ported improved regulatory compliance
after implementing an EMS.
Conclusions
The results of the discussions with indus-
try about environmental management sys-
tems suggest that the benefits routinely
exceed the expectations of those that im-
plement them. Apparently, the benefits of
environmental management systems are
not yet fully appreciated even among en-
vironmentally sophisticated companies.
As operating experience grows and com-
panies share information about their posi-
tive financial, environmental and mar-
keting experiences, it is likely that envi-
ronmental management systems will be
adopted by more and more organizations.
These discussions revealed an emerging
trend wherein large customer organiza-
tions are encouraging their many suppliers
to adopt environmental management sys-
tems. In a few cases, organizations are
requiring suppliers to register or conform
to an EMS standard. Over the next five
years this trend may result in a significant
change in environmental management
among US industry and quite possibly
among governmental organizations as
well.
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Question by Question Summary of Findings
The discussions with company representatives were conducted by telephone inter-
view. The interviewer took handwritten notes during the conversations, entered
the notes into a computer database for manipulation by various keywords and cri-
teria, and summarized the results question-by-question in the following sections of
this report.
1. Does your company have an environmental policy?
Findings
97%^p3o/o
Key Point
Frequently the Board of Di-
rectors has a committee that
addresses issues of environ-
ment, natural resources, and
social responsibility.
Notable Quotes
Yes, corporate has a company
policy and manufacturing op-
erations each have their own
policy refined to local needs.
Allergan Inc.
Absolutely! Since 1971 we
have had a worldwide envi-
ronmental policy.
IBM Corporation
Yes. Central theme and struc-
tures cover 5 major ^°hal
businesses. Corporate policy
statement and functional
procedures contained in a 3-
page document.
Lockheed-Martin
Discussion
All but one responding company has an
environmental policy. Many address envi-
ronment and natural resources in their
corporate mission statements.
Top management is involved and aware of
environmental management activities.
Frequently the Board of Directors has a
committee that addresses issues of envi-
ronment, natural resources, and social
responsibility. One responding company
said that they have an environmental ac-
tivist on the Board.
Corporate EH&S policy and performance is
usually communicated via a company's
website and, for many respondents, in an
annual environmental report that is dis-
tributed to shareholders, employees, and
to all others upon request.
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. Does your company have an environmental management system?
Findings
79°/J^T) No
^^21%
Key Point
Most responding companies
integrate environment, em-
ployee safety and health, and
resource conservation into a
single organizational func-
tion. Their environmental
management systems reflect
this integration.
Notable Quote
Our company has established
its own EHS management sys-
tem that parallels the format
of ISO 14000, ISO 9000, and
the Malcolm Baldridge Qual-
ity Award.
Baxter International
No, not in the modern sense
of the term. The Environ-
mental Compliance Evalua-
tion Program (ECE) is the
Navy's version of an Environ-
mental Management System.
US Navy SouthWestDiv
Discussion
Nearly four-fifths of the respondents have
an environmental management system in
operation in their company.
Most responding companies integrate envi-
ronment, employee safety and health, and
resource conservation into a single organ-
izational function. Their environmental
management systems reflect this integra-
tion.
The structure of the EMS tends to fall into
one of two camps, apparently a reflection
of corporate culture. Companies with a
central authority culture favor a central-
ized EMS that sets the standard for busi-
ness units and facilities. For example,
one respondent has obtained a corporate
global registration to ISO 14001. Individual
facility names are added to the corporate
registration document as they pass their
own third-party registration audit against
the corporate EMS.
Many companies have a culture favoring
business unit autonomy. Their environ-
mental management systems reflect dele-
gated authority in that their corporate
environmental policy and environmental
management systems serve as flexible
guidance for each business and facility to
craft its own policy and EMS to reflect its
unique market circumstances and perti-
nent local issues.
Environmental management systems also
vary considerably in scope among the re-
spondents. A few focus exclusively on
compliance with laws and regulations. The
majority incorporate the elements of
modern standards-based systems while
still strongly supporting compliance. Some
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are based on other principles such as
product lifecycle management. The latter
systems embrace sustainable development
more emphatically than ISO 14000.
The responses indicate that there are
varying definitions of "sustainability." Due
to the lack of a clear definition about
what constitutes sustainability-based envi-
ronmental management, the results of our
discussions with industry were inconclu-
sive on the subject of whether systems
based on sustainable development con-
cepts offer greater environmental or eco-
nomic benefit than systems based on
standards like ISO 14000 or regulatory
compliance.
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3. Do your company's environmental policy and management system con-
form to any recognized standards?
Findings
Yes^\ No
640/0 36%
Key Point
A two-thirds majority of re-
spondents have aliened their
EMS with an accepted envi-
ronmental management sys-
tems standard.
Key Point
The degree of effort ex-
pended on the alignment de-
cision by respondents suggests
that the ratio of firms
aligned vs. not-aligned to a
standard will not change
radically or quickly in the
future.
Notable Quotes
Company is currently looking
at improving their overall
system toward conformance
with ISO 14001 to better align
objectives and targets com-
pany-wide, and "be more
structurally sound."
Hewlett-Packard Company
All sites conform to EMAS and
75% conform to ISO 14001.
The emphasis on EMAS is due
to the parent company being
a European firm.
ST Microelectronics, Inc.
Discussion
A two-thirds majority of respondents have
aligned their EMS with an accepted envi-
ronmental management system standard.
Most often that standard is ISO 14001. The
European Eco-Management and Audit
Scheme (EMAS) was the only other stan-
dard mentioned. Some firms with opera-
tions in the United Kingdom previously
registered their UK facilities to BS 7750.
Most have now converted to ISO 14001.
Respondent comments reveal that those
whose environmental management sys-
tems conform to a recognized EMS stan-
dard made that decision after much inter-
nal deliberation.
Similarly, respondents whose environ-
mental management system are not in
conformance with a recognized standard
reported that they also carefully deliber-
ated that decision. Their management
teams concluded that conformance was
too costly in relation to the anticipated
benefits for their particular situation.
The degree of effort expended on the
alignment decision by respondents sug-
gests that the ratio of firms aligned vs.
not-aligned to a standard will not change
radically or quickly in the future.
Most companies opting to align with a rec-
ognized standard cited real or anticipated
market pressures. Pressures are related to
geographic markets, that is, having opera-
tions in an area of the world where the
environmental performance benchmark is
either ISO 14001 or EMAS registration.
Countries most often cited in this category
were the United Kingdom, Japan, Brazil
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and Singapore. One respondent mentioned
his recent visit to environmental minis-
tries in two African nations in conjunction
with his company's development plans.
Those two countries are considering the
possibility of "scrapping" their current en-
vironmental regulations~irr~favot^of ISO
14000. Certain European and Asian nations
were cited as markets that are starting to
recognize ISO 14001 registration as de
--facto evidence of environmental response,
biTTFyr——	 3	
Other reasons mentioned for alignment to
a standard focus on the desire to become
"more structurally sound and "more inter-
nally consistent on a global basis."
Reasons for not jtligning included lack of,
""market incentives, absence of customer
reauelts or requirements, inability to jus-
tify the cost and personnel time commit-
jrjent-toJimplement and maintain~conf6r-
mance to_a_standard. and desire to avoid
"bureaucracy" and "excessive documenta-
tion" that might hamper routine compli-
ance efforts.
No respondent cited lack of knowledge or
understanding about the basics of EMSs as
a reason for not aligning with an EMS
standard. More than one company noted
that poor economic conditions in their in-
dustry hindered the ability to move for-
ward with their EMS.
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4. Does your company conduct compliance audits on a regular basis?
Findings

Key Points
Over four-fifths of respondents
conduct regular audits for
compliance with environmental
regulations
Many respondents expressed a
belief that environmental
management systems improve
compliance with regulations
over traditional compliance-
focused programs.
Audits typically recur on a
three-year basis
The management systems ap-
proach focuses on the desired
result, not individual operator
or supervisor competency.
Notable Quote
Our company audits the envi-
ronmental management sys-
tem. The audit protocol con-
tains a compliance element.
Company conducts manage-
ment systems audits, not com-
pliance audits.
Varian Associates
Discussion
Over four-fifths of respondents conduct
regular audits for compliance with envi-
ronmental regulations or management sys-
tems audits that include a compliance
component.
Management systems audits are more
common in larger firms. There is a trend
toward management systems auditing at
the corporate level while facilities often
use a blend of compliance and systems
audit protocols. Many respondents ex-
pressed a belief that environmental man-
agement systems measurably improve
compliance with regulations over tradi-
tional compliance-focused programs.
Some firms also conduct policy audits to
verify site conformance to company pol-
icy.
Audits typically recur on a three year ba-
sis, however most respondents said that
the rate of recurrence is determined by
risk. Riskier activities are audited more
frequently, some on a daily basis.
One respondent explained the difference
between a compliance audit and a man-
agement systems audit: "Our old compli-
ance audit protocol would ask 'why isn't
there a label on the drum.' The new pro-
tocol asks 'show me the procedure for la-
beling drums."' The management systems
approach focuses on the desired result,
not individual operator or supervisor com-
petency. System failures are dealt with
through additional training, procedure re-
vision, and other operational control
mechanisms, rather than disciplinary ac-
tions which have a negative effect on mo-
rale and performance.
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Yes, the company conducts
about 65 compliance audits
per year on a sampling basis
from the company's total
population of 1,400 facilities.
Pacific Gas &
Electric Company
No, the company conducts
internal audits that we call
"facility assessmentsthese
incorporate a compliance
element.
Nike, Inc.
Respondents who do not conduct regular
compliance audits included design firms
primarily using contract manufacturers,
small firms with immature environmental
management programs, and performance-
based firms that focus on radical environ-
mental performance improvement through
major capital expenditures and bet-the-
business risks.
One respondent ran contrary to the trends
described above. Formerly managing their
environmental activities on the basis of
management systems audits, the company
had recently instituted a compliance audit
protocol as well.
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5. Does your company conduct pollution prevention audits on a regular ba-
sis? How frequently?
Findings
Yes
67%

No
33%
Key Points
A manufacturer will typically
save several dollars in mate-
rials cost for every waste dis-
posal dollar saved.
Companies associate pollution
prevention with both higher
cost and higher return than
waste minimization.
The driving force for imple-
menting pollution programs is
the potential for cost reduc-
tions as a result of reduced
waste disposal volume, re-
duced raw material pur-
chases, and tower contingent
environmental liability.
Notable Quote
Yes. PZ audits are a part of
the compliance audits. As a
CME member company does
an annual review for PI.
Rohm & Haas Company
Corporate does not conduct
P2 audits, but facilities do.
P2 is a component of the EMS;
each facility has one.
BHP World Minerals
Discussion
Respondents are broadly aware of the
benefits of pollution prevention and waste
minimization. Two-thirds conduct regular
pollution prevention audits. Benefits men-
tioned include lower waste disposal costs
combined with reduced consumption.
Several respondents pointed out the in-
herent leverage of the pollution preven-
tion "equation." A manufacturer will typi-
cally save several dollars in materials cost
for every waste disposal dollar saved.
Audit recurrence rates are not as consis-
tent for pollution prevention audits as for
compliance audits. Some conduct annual
audits and others do so on a two or three
year cycle. Sometimes the pollution pre-
vention audit is incorporated into the
compliance audit or the quality audit pro-
cess.
Companies associate pollution prevention
with both higher cost and higher return
than waste minimization. The emphasis on
either pollution prevention or waste
minimization varies among organizations
within an industry. When an external force
encourages pollution prevention within an
industry or for a government agency, pol-
lution prevention gets the emphasis. Ex-
amples are the chemical industry's Re-
sponsible Care program and, for govern-
ment, the Presidents Executive Order on
Pollution Prevention. The chemical indus-
try's Responsible Care program sets a
standard that applies to all members of
the Chemical Manufacturer's Association.
Responsible Care includes a pollution pre-
vention component with the result that
most organizations in the chemical indus-
try focus on pollution prevention as op-
posed to waste minimization. Many com-
panies not recognized by the public as
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chemical manufacturers (e.g. major oil
companies) have large business units that
manufacture chemicals and are CMA
members.
Respondents seem to associate waste
minimization with process efficiency. They
associate pollution prevention with
broader process and product change. Ex-
tractive and process industries (mining,
oil, chemical) are more likely to view
waste minimization as a source of profit
and integrate that philosophy into opera-
tions and company culture. Companies
from many industries, especially firms
with advanced environmental programs,
also see pollution prevention as a source
of revenue, mainly from recycling and
from waste disposal cost savings.
The driving force for implementing pollu-
tion programs is the potential for cost re-
ductions as a result of reduced waste dis-
posal volume, reduced raw material pur-
chases, and lower contingent environ-
mental liability. Many organizations report
their pollution prevention gains in their
annual report or in an annual environ-
mental report.
In summary, two-thirds of companies con-
duct pollution prevention audits on some
regular basis. Many of those companies
realize a financial benefit from their pol-
lution prevention programs. On the other
hand, pollution prevention programs ap-
pear to be much less formalized than
compliance programs. This is a paradox
since pollution prevention was often men-
tioned as a financially beneficial activity
while compliance was generally viewed as
a cost of doing business.
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6. Describe your method of determining your company's environmental as-
pects and impacts?
Findings
Key Point
The most popular methods
used by the respondents to
identify their company's envi-
ronmental aspects and im-
pacts are process mapping,
materials usage analysis, risk
assessment, functional analy-
sis, and combinations of these
approaches.
Notable Quotes
We use a mass balance ap-
proach, asking, "what hap-
pens to our materials?" In
part we rely on industry in-
formation and research. Our
industry association has pub-
lished reports about CFCs,
global warming gasses, elec-
tricity use, waste minimiza-
tion, and other subjects.
LSI Logic Corporation
Our company uses the term
"Business Interaction" rather
than "aspects and impacts" to
describe the environmental
effects of its operations. We
look at material consumption,
wastes from processes, etc.
Allied Signal Aerospace
Using our Statement of Work
for Air Force, we took posi-
tion titles and matrixed the
input and output resources.
The matrix guided the aspects
and impacts evaluation.
United Paradyne Corporation
Discussion
Respondents named the following ap-
proaches for identifying environmental
aspects and impacts.
>	Process mapping.
>	Risk assessment.
>	Mass balance.
>	Lifecycle assessment.
>	Functional analysis.
>	Multidisciplinary team.
>	Checklist.
>	Materials usage analysis.
^	No method. ^
About half of the respondents stated that-
they have no method for determining en-
vironmental aspects^and impacts, al-
^RouglTmost understood~tfie meaning_of-
those terms as defined in the ISO 14000
standards.
The remaining half of the respondents
(about 16 companies) use 8 different
methods to identify environmental aspects
and impacts.
The most popular methods used by the
respondents to identify their company's
environmental aspects and impacts are
process mapping, materials usage, risk
assessment, functional analysis, and com-
binations of these approaches.
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7. Describe your method of determining the relative significance of your
environmental aspects and impacts?
Findings
Key Points
Respondents identified at
least 20 criteria for evaluat-
ing the significance of their
environmental aspects and
impacts.
The most commonly men-
tioned method of computing a
"significance ranking" employs
multiple criteria and qualita-
tive weighting of various cri-
teria.
Notable Quotes
There is a corporate proce-
dure of risk evaluation and
response addressing EHEtS,
process engineering, prob-
ability and consequence, and
analysis of management risks.
Occidental Petroleum
Corporation
Significance is based on the
quantities of materials, sig-
nificance of toxin content
(teratogens, mutagens); these
tend to "jump out" at you.
Company has an internal sys-
tem to evaluate the environ-
mental impact of products
against a lifecycle assessment
model of the ideal product.
They assess about six dimen-
sions to determine how far
afield the real product is
from the ideal.
Patagonia
Discussion
Few companies follow a systematic proce-
dure for determining significance of envi-
ronmental aspects and impacts. No single
methodology dominated the responses.
Generally the responses indicate that the
more closely aligned to ISO 14001, the
more rigorous the aspects and impacts
determination procedure.
Respondents identified the following crite-
ria for evaluating the significance of their
environmental aspects and impacts.
>	Payback.
>	Cost.
>	Legal and regulatory requirements.
>	Likelihood of occurrence.
>	Risk or hazard posed.
>	Severity.
>	Loading.
>	Duration.
>	Frequency.
>	Aspect-to-impact linkage.
>	Public concerns.
>	Stakeholder concerns.
>	Public image.
>	Ability to control.
>	Difficulty to fix.
>	Effects on process and procedures.
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>	Professional judgement.
>	Threshold setting.
>	Qualitative ranking.
The most commonly mentioned method of
computing a "significance ranking" em-
ploys multiple criteria and qualitative
weighting of various criteria. A computer
spreadsheet is used to perform the com-
putations and sort the results by rank or
priority.
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Does your company measure its environmental performance or use envi-
ronmental performance indicators? Please describe.
Findings
Yes
82% (
No
'18%
Key Points
Over 80 percent of respon-
dents use environmental per-
formance indicators (EPIs) to
measure the performance of
their environmental manage-
ment systems.
Using ratios as environmental
performance indicators re-
sults in an EPI that can be
tracked over time in graphs
and tables.
Notable Quote
We're measurement 'fools;'
we track everything.
Allergan Corporation
Yes. Our company has many
EH&S performance indicators.
"Success sharing" is tied to
these.
Chevron Corporation
Discussion
Over 80 percent of respondents use envi-
ronmental performance indicators (EPIs)
to measure the performance of their envi-
ronmental management systems. The
most frequently mentioned performance
indicators focus on the following items.
>	Recycling rates.
>	Energy use.
>	Water use.
>	Emissions.
>	Regulatory notices of non-
compliance.
>	Solid waste volume.
>	Hazardous waste volume.
Quantitative data is frequently converted
to a ratio by dividing the measured vari-
able (e.g. solid waste volume) by another
variable that has broad significance to the
business (e.g. units produced).
Using ratios as environmental perform-
ance indicators results in an EPI that can
be tracked over time in graphs and tables.
It serves as a visual record of the organi-
zation's environmental continuous im-
provement program.
Respondents cited three key business vari-
ables used in EPIs.
>	Unit sales.
>	Unit production.
>	Unit activity.
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Respondents offered many comments
about their EPI programs. A few are noted
below.
>	Company's bonus program is tied to
environmental performance.
>	Bright line tests of what is good
environmental performance are
hard to define; company working
on this.
>	Company develops "leading indica-
tors" to signal declining perform-
ance and take early corrective ac-
tion.
>	Company is driven to add more
value to their EH&S program by
utility deregulation; they believe
that ISO 14000 and information
systems will do so.
>	"You name it, we track it."
>	Company has a corporate energy
council.
>	Company uses their audit system to
accumulate data for EPIs.
>	The "consumer driver" for environ-
mental performance has not mate-
rialized.
>	"We're measurement fools; we
track everything."
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. Does your company have a mechanism for community participation
and tor public information sharing about its environmental perform-
ance?
Findings
No
73%^/27%
Key Points
Seventy three percent of re-
spondents said they sponsor
some form of community par-
ticipation or public informa-
tion sharing about their com-
pany's environmental per-
formance.
Beyond the annual environ-
mental report and corporate
website, the responses do not
show any pattern or accepted
system of community out-
reach that might serve as
guidance for others.
Notable Quote
Yes, our company periodically
publishes an 'annual' envi-
ronmental report and plans to
do so annually. Individual fa-
cilities publish community
newsletters. A Washington
State refinery is sponsoring a
Heron rookery nearby.
Atlantic Richfield Company
(ARCO)
Discussion
Seventy-three percent of respondents said
they sponsor some form of community
participation or public information sharing
about their company's environmental per-
formance.
The annual environmental report and cor-
porate website are the most widely used
communication vehicles. Some organiza-
tions participate on community advisory
panels that may be focused on their facil-
ity, or on a special natural resource in the
community like a riparian habitat or wet-
land. A few respondents mentioned that
they provide financial support for commu-
nity environmental programs or to larger
environmental organizations, and one firm
offers technical grants for the community
to hire a consultant to advise them on
new projects the company proposes in
their community.
One respondent (a technology firm) said
their company sponsored "household haz-
ardous waste" disposal days. One firm
mentioned that they have an environ-
mental activist on their Board of Direc-
tors. Beyond the annual environmental
report and corporate website, the re-
sponses do not show any pattern or ac-
cepted system of community outreach
that might serve as guidance for others.
One respondent said that their firm is in
the process of developing corporate
guidelines for community outreach.
A number of respondents said that they
have scaled back their previous commu-
nity programs because of poor turnout for
"open house" events and similar functions.
Their conclusion was that the community
was not interested.
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10. Has your company's environmental management system improved your
company's environmental performance? Please describe.
Findings
Yes
79%
e
No
21%
Key Point
An environmental manage-
ment system helps focus re-
sources and assets, results in
better business integration of
economic and environmental
priorities, and improves op-
erational control.
Notable Quote
You cannot have consistently
good environmental perform-
ance without a management
system.
Atlantic Richfield Company
(ARCO)
Planning activities in prepara-
tion for new State require-
ments for pollution preven-
tion has had a positive impact
on environmental perform-
ance.
Burr-Brown Corporation
(Semiconductors)
Discussion
Nearly 80 percent of respondents believe
that their environmental management sys-
tem (EMS) has improved their company's
environmental performance. Respondent
comments clustered around three key
benefits of the EMS.
>	An environmental management
system helps focus resources and
assets on areas promising greatest
combined economic and environ-
mental return on investment.
>	An environmental management
system results in better business
integration of economic and envi-
ronmental priorities and helps to
merge the EHEtS function into op-
erations and corporate decision-
making.
>	An environmental management
system results in improved opera-
tional control that in turn results in
less waste and higher resource
productivity.
Respondents offered numerous comments
on this question; there was clear enthusi-
asm somewhat in proportion to the length
of time that the company has been oper-
ating under a "modern" EMS.
>	"You cannot have consistently good
environmental performance with-
out a management system."
>	'The key impact of our EMS is to
get people involved."
>	"We use audit findings to define
the annual focus for performance
improvement. Our system is de-
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signed to identify issues, assign re-
sponsibility, act, check, and im-
prove performance."
>	"The key elements are training,
communication, calibration, and
operational controls."
>	'Systematic integration of our EMS
into the design department drives
down product lifecycle costs."
>	"When you drive around our facility
(a copper mine) you can really see
the improved general housekeep-
ing.'"
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11. What are the key elements of your environmental management system
that most contribute to improved environmental performance?
Findings
Key Point
Respondent comments touch
on nearly all elements of an
ISO 14001 or EMAS environ-
mental management system.
The results reflect the fact
that the EMS concept has
broad applicability across in-
dustry sectors and institu-
tional types.
Notable Quote
Pollution prevention is the
key element to improve envi-
ronmental performance,
along with good waste man-
agement practices that help
cut costs and liabilities.
Baxter International, Inc.
Discussion
Respondents identified 25 items as key
elements of their environmental manage-
ment systems that "most contribute" to
improved environmental performance.
1.	Integrated nature of the EMS (i.e. sepa-
rately managed but similar processes or-
ganized under one "umbrella").
2.	Objectives and targets; annual goals.
3.	Pollution prevention.
4.	Management support and resource allo-
cation.
5.	Measurement systems.
6.	No component key element; the entire
system is the key element.
7.	Performance measurement and audits.
8.	Regular measurement, monitoring and
reporting for early warning.
9.	Public reporting is a powerful motivator.
10.	Communication and training.
11.	Transition from a person-dependent to a
system-dependent approach.
12.	Risk assessment methodology of priori-
tizing activities.
13.	Integrating EMS into operating systems
and human resources programs.
14.	Leadership, integration, planning, pro-
cedures, resources.
15.	Obligation to perform.
16.	Making environment an "embedded
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ethic," avoiding the tradeoff mentality.
17.	Focus on operational control, documen-
tation, and the plan/do/check/act
quality cycle.
18.	Environmental performance indicators.
19.	Standard operating procedures.
20.	Working openly with government.
21.	The environmental audit system.
22.	In-house experts on pollution preven-
tion, EMS, other.
23.	Management review and registrar sur-
veillance audits.
24.	Environmental awards programs.
25.	Benchmarking.
Respondent comments touch on nearly all
elements of an ISO 14001 or EMAS envi-
ronmental management system. There
were nearly as many answers to the "key
element" question as participants in the
survey. The results reflect the fact that
the EMS concept has broad applicability
across industry sectors and institutional
types. Individual organizations identify
one or a few components as "key ele-
ments" because that element has been
observed to contribute the most in their
particular situation.
The consensus seems to be that there is
no single element or group of elements
within an EMS that is more valuable than
others. It is the environmental manage-
ment system as a whole that is of greater
value than more traditional approaches to
environmental management.
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12. Are you encouraging or requiring your suppliers to implement environ-
mental management systems?
Findings
Yes
640/W)No
^^36%
Key Point
Some respondents used words
like "strongly encourage" to
indicate the degree of pres-
sure placed on suppliers to
run a good ship.
Two respondents have noti-
fied suppliers (several hun-
dred each) that within a few
years (3 or so) they will re-
quire registration to a stan-
dard as a condition of doing
business.
Several companies said that
they would not mandate sup-
plier environmental manage-
ment systems, but they would
look closely at their supplier's
compliance record.
Notable Quote
Yes, very much so. Our com-
pany works with suppliers and
contractors, jobbers, proces-
sors, to make them aware of
company's expectations.
Chevron Corporation
Our primary focus is on our
contractors because they rep-
resent a large portion of our
potential environmental li-
Discussion
Nearly two thirds of respondents encour-
age suppliers to implement environmental
management systems.
Two respondents have notified suppliers
that within a few years (3 or so) they will
require registration to a standard as a
condition of doing business. They excuse
registered suppliers from the company's
regular supplier audits. Another respon-
dent has sent a letter to several hundred
suppliers encouraging them to "embrace"
ISO 14001.
In contrast to the pattern of customers
auditing suppliers about environmental
performance, one respondent said their
chlorine supplier had approached the
company to assure safe use of its products
by the customer. The supplier's action was
prompted by its adherence to the Chemi-
cal Industry's Responsible Care program.
Thus it appears that environmental man-
agement systems have the power to influ-
ence behavior both "up" and "down" the
supply chain.
For many companies, contractors are their
primary contingent environmental liabil-
ity. Industries such as petroleum, mining,
apparel and the military utilize contrac-
tors extensively to accomplish their mis-
sions.
Respondents generally indicated that they
are comfortable mandating a good record
of compliance with environmental and
other regulations from their contractors
and suppliers. This attitude manifests
through vendor questionnaires, environ-
mental, health and safety purchasing cri-
teria, and supplier audits. Some respon-
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ability. The company has a
tight purchasing screen for
contractors and suppliers
based on there EH&S record.
Homestake Mining Company
dents used words like "strongly encourage"
to indicate the degree of pressure placed
on suppliers to run a good ship.
One respondent mentioned that ISO 9000
had resulted in increased interactions
with suppliers and anticipated a similar
benefit from ISO 14000.
Several companies said that they would
not mandate supplier environmental man-
agement systems, but they would look
closely at their suppliers compliance rec-
ord.
One respondent who is knowledgeable
about government contracting said that
ISO 9000 and ISO 14000 are both under
consideration as future DOD/DOE con-
tracting requirements.
Comments from respondents indicate that
the organizations with more mature envi-
ronmental management systems or
ISO/EMAS registration are more comfort-
able in encouraging their suppliers and
contractors to look closely at the benefits
of adopting an EMS.
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13. Has operating under an environmental management system resulted in
economic benefits to your company? Please describe.
Findings
Yess^N No
5Q%\j42%
Key Point
Environmental accounting
helps reveal the financial
benefits that are otherwise
intangible or hidden in oper-
ating overhead. Four firms
who use environmental ac-
counting systems reported
financial gains of S1 million
(total), $2 million per year,
S40 million over 5 years, and
$100 million over 8 years.
Notable Quotes
Yes, we've seen savings in
electricity and water usage,
solid waste disposal. We have
improved our design process,
and public recognition of our
achievements is evident.
ST Microelectronics, Inc.
Sure. Recycling income at one
large plant is over $2 million
per year (mainly plastics).
Baxter International, Inc.
Discussion
The "economic benefits of an EMS" ques-
tion was challenging for most respondents
to answer.
Respondents generally agreed that an EMS
should result in certain financial savings.
However, only 58 percent were able to
confirm that their company's EMS had de-
livered the anticipated returns.
Respondents from the extractive indus-
tries (mining, petroleum) noted that an
EMS implementation led to difficult deci-
sions about expensive capital projects.
Their companies already operate in com-
pliance with laws and regulations. To im-
prove, they may be driven to address en-
vironmental aspects that are not regula-
tory-driven, but that would result in a net
benefit to the environment if imple-
mented. Such "voluntary" actions are of-
ten controversial because the benefits are
mostly intangible.
Those respondents that use environmental
-financial accounting were more able to
affirm the economic benefits of operating
an EMS. Environmental accounting helps
reveal the financial benefits that are oth-
erwise intangible or hidden in operating
overhead. Four such firms reported finan-
cial gains of $1 million (total), $2 million
per year, $40 million over 5 years, and
$100 million over 8 years. One company's
waste disposal costs declined from 15 per-
cent of total cost to less than one percent
under their EMS. Most respondents that do
not measure environmental financial re-
sults say that they suspect that they do
have measurable savings.
The most frequently mentioned areas of
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economic benefit include the following.
>	Cost avoidance (fines 8t penalties
etc.)
>	Waste disposal reductions.
>	Lower total costs for materials.
>	Faster permit turnaround.
>	Improved image and recognition
from agencies and the public.
Several companies believe that the
amount of economic benefit a company
achieves is a function of the strength of
its environmental accounting system.
A few respondents mentioned that the fi-
nancial community, particularly the ma-
jority of Wall Street analysts, is not con-
vinced that environmental management
systems provide for significant risk reduc-
tion.
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14. Are the economic benefits (identified in your comments on the previous
topic) associated with any particular element of your environmental
management system?
Findings
Yes^\ No
610/0^/39%
Key Point
Many respondents said that
the people who can really
change things in terms of en-
vironmental performance are
on the production line. The
EMS helps get them involved.
Notable Quote
Yes, mainly with waste man-
agement, waste minimiza-
tion, and recycling.
Arizona Electric Power
Cooperative
Operational controls and good
procedures make a huge dif-
ference because you're more
on top of production varia-
tions that result in compli-
ance excursions."
Skyway Freight Systems
Discussion
Three-fifths of respondents associated
economic benefits with particular ele-
ments of the EMS, including the following.
>	Goals and objectives.
>	Key performance indicators.
>	Operational controls.
>	Measurement.
>	Standard operating procedures.
>	Training.
>	The aspects and impacts process.
>	Resource allocation to priorities.
>	In-house expertise such as a dedi-
cated pollution prevention expert.
>	Management system audits.
>	Pollution prevention.
>	Pushing responsibility down into
the organization.
Respondent comments about the activities
that most contribute to economic gains
are summarized below.
>	Measurement.
>	Prioritization.
>	Goals.
>	Controls.
>	SOPs (standard operating proce-
dures).
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>	Pollution prevention.
>	Delegation.
>	Empowerment.
One respondent considers the company's
unique approach to identifying and priori-
tizing its environmental aspects as the
driver of its economic gains from envi-
ronmental management. Their system pri-
oritizes continuous improvement projects
on two criteria: environmental impact and
potential economic gain. Thus they focus
resources on those areas with the highest
ROI potential and those most likely to
benefit the environment.
Another respondent pointed to strong
communications and interactions with
plant operators during negotiations with a
local air quality agency for a Title V per-
mit. Operator input combined with agency
flexibility resulted in permit conditions
that minimized negative economic conse-
quences for the company while meeting
all regulatory requirements.
Many respondents said the people who can
really change things in terms of environ-
mental performance are on the production
line. The EMS helps get them involved.
One respondent commented that too
much emphasis on production at the ex-
pense of pollution control is a poor strat-
egy. When the pollution control system
failed, the company experienced major
excursions above discharge limits and was
subject to fines and penalties. Addition-
ally, production was shut down. An EMS
can help to integrate and equalize priori-
ties in such a situation.
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15. What elements of an environmental management system are necessary
to assure compliance with environmental regulations?
Findings
Notable Quotes
The system itself is the key.
Without it you are at risk.
Training is important. You set
the biggest bang for the buck
by training the people on the
shop floor.
Lockheed-Martin Corporation
It's not the ems. Attitudes
matter - it's a people thing.
Quantum Corporation
Management review, auditing.
These prevent things from
"falling down. "
Rohm and Haas Company
Discussion
Respondents identified the elements of an
environmental management system that
are necessary for compliance.
>	A policy commitment to maintain
environmental regulatory compli-
ance.
>	Management involvement, support
for the policy, and periodic man-
agement review.
>	Standard operating procedures for
good operational control and
equipment calibration.
>	Training.
>	A legal and regulatory change-
tracking method.
>	Good document control.
>	Audits, both management systems
and compliance types.
>	Standardized corrective action
procedures with management sign-
off.
>	Good performance indicators,
preferably leading indicators.
Other items and approaches mentioned to
help stay in compliance when operating
under an EMS included the following.
>	Electronic databases (Environ-
mental Information Management
Systems).
>	Prioritization - programs must ad-
dress real priorities.
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>	Good attitudes on the part of the
workforce; pride in the workplace.
>	Corporate culture; support for a
systems mentality.
>	Excellence or sustainability meet-
ings including many departments.
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16. Has your company's environmental management system improved your
company's compliance with environmental regulations?
Findings
Yes&\
7°%my
Key Point
Respondents cited their EMS
as responsible for a general
improvement in environ-
mental awareness among the
workforce.
Some respondents said that
while it was not clear that
compliance had improved
measurably under their EMS,
because the company had ex-
cellent compliance record
prior to implementing the
EMS, it was clear that with-
out an EMS compliance would
decline.
Responses indicate a growing
trend toward applying US
regulatory standards to global
operations for consistency
throughout a company, espe-
cially when that company is
registering to a recognized
standard.
Notable Quote
Yes. Ask the converse ques-
tion. Without the EMS com-
pliance would likely not be as
good.
Hewlett-Packard Company
Discussion
Seventy percent of respondents said that
their environmental management systems
had contributed to improved environ-
mental regulatory compliance. Evidence
cited included the following.
>	Reduced number of Notices of
Violation.
>	Reduced monetary fines and penal-
ties.
>	Reduced number of citizen law-
suits.
>	Positive trends in key performance
indicators.
Respondents cited their EMS as responsible
for a general improvement in environ-
mental awareness among the workforce.
This results in heightened activity to cor-
rect potential compliance excursions in
advance of the actual event. Proactive
behavior, enabled by tracking perform-
ance indicators as well as just better
watchfulness by the workforce at large,
yields positive results with regard to com-
pliance.
Some respondents said that while it was
not clear that compliance had improved
measurably under their EMS, because the
company had an excellent compliance re-
cord prior to implementing the EMS; it
was clear that without an EMS, compli-
ance would decline.
Several respondents said that their foreign
operations benefitted most from their EMS
because they operate in countries where
environmental regulations are loosely or
not enforced. The EMS provided the com-
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Yes, to some degree. Now
they can deal with issues
rapidly due to better, faster
reporting and information
exchange.
Nike, Inc.
pany with better operational control in
these offshore facilities than would reli-
ance on local regulatory enforcement. Re-
sponses indicate a growing trend toward
applying US regulatory standards to global
operations for consistency throughout a
company, especially when that company is
registering to a recognized standard.
Several respondents who are responsible
for their firm's compliance mentioned the
continuous improvement element as the
key factor driving better compliance.
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17. Should environmental management systems be encouraged by regula-
tory agencies?
Findings
YeS,^^ M
82*/'C),e%
Key Point
Eighty-two (82) percent of
respondents said that envi-
ronmental management sys-
tems should be encouraged by
regulatory agencies.
Nearly all respondents wres-
tled with the term "encour-
aged" out of fear that today's
prodding could become to-
morrow's mandate.
Notable Quote
A company does not need an
environmental management
system to do a good job man-
aging its environmental re-
sponsibilities and perform-
ance; however, its hard to do
a good job without one.
Patagonia, Inc.
Discussion
Eighty-two percent of respondents said
that environmental management systems
should be encouraged by regulatory agen-
cies.
Nearly all respondents wrestled with the
term "encouraged" out of fear that today's
prodding could become tomorrow's man-
date. Most said that it would be a mistake
to mandate environmental management
systems. The commonly stated position
was this:
>	Don't mandate adoption of a par-
ticular standard.
>	Don't mandate registration to a
standard.
>	Don't mandate conformance to a
standard.
Two respondents said that there is a "huge
advantage" to environmental management
systems. "They are a powerful tool for
change."
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18. What factors did your company consider in your decision to adopt an en-
vironmental management system?
Findings
Key Point
Organizations spend signifi-
cant time on the issue of how
to manage their environ-
mental responsibilities and
whether to adopt ISO 14000.
The results indicate that the
respondents to this survey are
clear about their position on
the benefits and drawbacks of
environmental management
systems in their own com-
pany.
Notable Quotes
Our company is mainly con-
sidering a global view of the
need to conform to customer
requirements. ISO 14001 may
become the benchmark.
LSI Logic Corporation
The Chairman felt that a
strong EMS was essential to
be a global vendor.
Thermatrix, Inc.
(Pollution control equipment)
Our EH&S group has the de-
sire to be strongly in the
quality loop and is aligning
with the company's ISO 9000
quality program to facilitate
EMS deployment."
Skyway Freight Systems, Inc.
Discussion
Virtually all respondents said that their
organization had spent significant time on
the issue of whether to adopt an EMS and
whether to conform to a recognized stan-
dard. The results indicate that respon-
dents are clear about their position on the
benefits and drawbacks of an EMS in their
own company.
Respondents cited 29 factors that affect
the decision to adopt an environmental
management system. Six broad themes
emerged.
Environmental management systems:
>	Overcome weaknesses in existing
compliance programs.
>	Are a unifying force, especially in
geographically dispersed organiza-
tions.
>	Support policy, quality, proactive
management, sustainability, and
social responsibility.
>	Help manage risk.
>	Build buyer confidence in a sup-
plier's sustainability.
>	Foster leadership and motivate
employees.
Mom and apple pie? Negative comments
about environmental management systems
were rarely mentioned in the discussions
with the leading companies that partici-
pated in this survey. That includes the 36
percent who currently do not intend to
conform to a recognized standard. We at-
tribute this to confidence in the "systems
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approach" that has worked well in other
areas like communications, quality, and
accounting.
Respondent comments about environ-
mental management systems are listed
below.
>	"We appreciate the formality [of an
EMS]; it fits with our accepted work
practices." [Comment made by an ISO
14001 registered company]
>	"A natural fit with our six sigma [qual-
ity] program, continuous improvement
mentality and systems orientation."
>	"Opportunity for broader involvement
of all personnel."
>	"Helped resolve a major operational
issue that had us on the front page of
the Wall Street Journal almost
weekly."
>	"Our regulatory burden as a public
utility is considerable; our EMS helps
assure that all relevant information is
available at all times to the people
who need it."
>	"We had observed some weaknesses in
our company's already strong compli-
ance program. The EMS looked like a
better way."
>	"We had a desire to improve uneven'
performance among businesses and fa-
cilities; we lacked a common approach
such that it was difficult to pull to-
gether company initiatives worldwide.
The EMS fixed that."
>	"We [EH&S professionals] had a desire
to demonstrate improved due dili-
gence to senior management."
>	"We wanted to get away from depend-
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ence on individuals."
>	"We wanted to conform to ISO 14001
>	"Some important customers were ask-
ing for it [ISO 14001 registration]."
>	"Compliance is no longer enough; risk
management is required."
>	"The EMS helps maintain our license to
operate.'"
>	"Our decision was not customer driven;
the registration driver is linked to
geographic markets."
>	"ISO 14001 helps execute policy more
effectively."
>	"ISO 14001 is a differentiator."
>	"ISO 14001 is consistent with our cor-
porate commitment to excellence."
>	"The primary factor [for EMAS registra-
tion] was customer demand."
>	"Our EMS gives us a common language
across our corporate demographics."
>	"The EMS has the potential to reduce
overhead and transfer best practices."
>	"We wanted to be ahead of the game.
ISO 14001 may become a requirement,
the benchmark."
>	"We desired to achieve integration and
consistency."
>	The SEC required us to implement an
EMS in 1980."
>	"Any large company would be out of its
mind not to track [environmental in-
formation]".
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19. Did sustainable development concepts influence your decision to adopt
an environmental management system? Please describe.
Findings
Yes^^\ No
73%^/27%
Key Point
Respondents see a clear link
between sustainable devel-
opment and continuous im-
provement.
Notable Quotes
Yes, we have analyzed the
environmental impact of our
products, like household
bleach, through Lifecycle As-
sessment and other means.
We have also considered bio-
degradability issues.
The Clorox Company
Sustainable development con-
cepts were a driving force for
EMS implementation, espe-
cially for our Asian operations
where government agencies
don't enforce their environ-
mental regulations.
Integrated Device Technology
Sustainable development is
the foundation of company's
ems. We believe that
"sustainability thinking" will
increase the bottom line and
set us apart from the compe-
tition.
ST Microelectronics, Inc.
Discussion
Nearly three-fourths of the respondents
said that sustainable development con-
cepts influenced their company's decision
to adopt an environmental management
system.
The most frequently cited elements of
sustainable development mentioned as
important for business were the following.
>	Recycling.
>	Pollution prevention.
>	Waste minimization.
>	Social responsibility to indigenous
peoples.
>	Energy efficiency and resource
conservation.
>	Lifecycle impact reduction.
Two respondents said that sustainable de-
velopment was the "foundation" of their
EMS. Interestingly, one company is ISO
14001 registered; the other has no inten-
tion of adopting either ISO 14001 or an
EMS. Both have exceptional reputations
for environmental consciousness and per-
formance.
Respondents see a clear link between sus-
tainable development and continuous im-
provement.
Maintaining the social license to operate is
a significant concern in the extractive in-
dustries (e.g. petroleum and mining).
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20. How are sustainable development concepts or values reflected in your
ems, if at all?
Findings
Key Point
Defining a company's envi-
ronmental aspects and im-
pacts and linking the results
to the continuous improve-
ment process is the business
translation of sustainable de-
velopment.
Notable Quotes
Natural step; industrial ecol-
ogy.
Patagonia, Inc.
Sustainable development con-
cepts are integrated into the
EMS through our commitment
to the prevention of pollution
and our policy of "meeting or
surpassing" regulatory re-
quirements.
United Paradyne Corporation
Recycling, energy conserva-
tion; our company has spent
millions of dollars in these
areas.
Pacific Gas ft Electric
Company
Discussion
Sustainable development concepts are re-
flected in a company's environmental
management system in a variety of ways.
>	Waste reduction policy.
>	Continuous improvement.
>	Material substitution programs.
>	Aspects and impacts procedures.
One firm said that defining a company's
environmental aspects and impacts, and
linking the results to the continuous im-
provement process, is the business trans-
lation of sustainable development.
Although many are familiar with the term
"sustainable development" and its princi-
ples, only a few respondents have explic-
itly integrated sustainable development
into their management practices.
Look at our policy on the
website. You will see resource
conservation, P2, the waste
management hierarchy;
moving design-for- environ-
ment upstream into R&D.
IBM Corporation
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21. Did regulatory compliance issues influence your decision to implement
an environmental management system?
Findings
Yestf^\No
45%^_Jss%
Key Point
Fixed base industries with
heavy chemical use, generally
subject to heavy environ-
mental regulation and en-
forcement, are most likely to
see environmental manage-
ment systems as a way to im-
prove compliance.
Notable Quote
Yes, the desire for improved
compliance was a big part of
the decision.
Alta Plating and Chemical
Corporation
We looked at it this way: coun-
tries that do not have effective
environmental regulatory pro-
grams are most in need of envi-
ronmental protection. Because
we operate in many of those
countries, we built minimum
operational standards into our
EMS. Now supervisors in those
countries have no excuse for not
performing to the company's
minimums, although they for-
merly objected to EHEtS requests
on the basis of "no compliance
requirement." Thus "lack of com-
pliance issues was a major driver
for implementation of an ems."
BHP World Minerals
Discussion
Slightly less than half of the respondents
said that regulatory compliance issues af-
fected their decision to adopt an envi-
ronmental management system. The re-
sponses tended to group around industries
to some extent.
>	"Yes" responses were common
among firms in the chemical, con-
sumer product, electric utility and
metal finishing industry.
>	"No" responses were noted in the
apparel and freight industries.
>	No pattern was apparent in the
mining, oil, aerospace and elec-
tronics industries.
The common thread here is that fixed
base industries with heavy chemical use,
that are generally subject to heavy envi-
ronmental regulation and enforcement,
see EMS as a way to improve compliance.
In industries where regulatory agency
scrutiny and enforcement are less strin-
gent the decision about EMS adoption was
understandably less influenced by compli-
ance issues.
The primary concern for those who see
compliance issues as an EMS driver is to
become more proactive, to be more "on
top of the issues." In contrast, one re-
spondent said that a lack of environ-
mental compliance issues could be a
driver for EMS adoption. This person cited
the need for better operational controls in
regions where regulations are lax, in order
to assure good environmental perform-
ance and minimize risk.
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22. Are there internal or external barriers to implementing an environ-
mental management system, and what are they?
Findings
Yes
55%
€>
No
45%
Key Point
The responses suggest that
the positive results obtained
from implementing an envi-
ronmental management sys-
tem, such as better opera-
tional control, improved mar-
ket acceptance and real fi-
nancial returns, tend to bal-
ance concerns about time
commitment, new paperwork,
cost, and workforce resis-
tance to change
Notable Quote
People were afraid of the
amount of time that would be
required. However, results
demonstrated the significant
paybacks and avoided costs.
Baxter International, Inc.
Internal barriers yes, external
no. We had to sell top man-
agement on the concept.
Eventually the CEO became
convinced that market de-
mands would push us, and
growing public concerns about
environment pull us in direc-
tion of ISO 14000. He became
convinced of the benefits and
said, "do it."
Integrated Device Technology
Discussion
Slightly over half (55%) of the respondents
said that there are internal barriers to im-
plementing an environmental manage-
ment system. No one identified external
barriers.
Some said there were both internal and
external incentives to implement an EMS.
>	45 percent of respondents saw no
barriers to implementing an EMS,
>	Several perceive a mixture of in-
ternal barriers and incentives, and
>	Respondents are unanimous that
there are no external barriers.
Commonly cited internal barriers in-
cluded:
>	Limited resources (people, money,
expertise, etc.).
>	Long payback time for EMS invest-
ments.
>	Possibly no payback at all.
>	Increased "bureaucracy,"
work, documentation.
paper-
>	Personnel resistant to change.
>	The "distraction factor;" diversion
of attention from routine compli-
ance tasks.
>	Staff concerns about "loss of influ-
ence."
>	Management and supervisory ob-
jections to taking voluntary actions
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that are not mandated by regula-
tions.
>	Excessive time commitment.
>	The "startup burden;" referring to
the work effort required to design
and implement an environmental
management system.
Commonly cited incentives for an EMS in-
cluded:
>	"The CEO says 'do it;'" i.e. the cor-
porate mandate.
>	Customer requirements.
>	Geographic market expectations.
>	Perceived fast payback.
>	Improved image.
>	Better operational control.
The responses suggest that the positive
results obtained from implementing an
environmental management system, such
as better operational control, improved
market acceptance and real financial re-
turns, tend to balance concerns about
time commitment, new paperwork, cost,
and workforce resistance to change
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23. What are the critical factors for successful implementation of an envi-
ronmental management system?
Findings
Key Point
In short, the critical success
factors are leadership, train-
ins, empowerment, and en-
thusiasm.
Notable Quotes
Success depends on how you
market the EMS concept
within your company: why
you want to do it. Place em-
phasis on elimination of re-
dundancies, utilization of ex-
isting systems.
Skyway Freight Systems
It is critical to align the sys-
tem up and down the organi-
zation; senior and line man-
agement need to be coordi-
nated on the desired out-
comes. Available resources,
people, money; holding peo-
ple accountable are all im-
portant.
IBM Corporation
Develop a formalized man-
agement system, introduce
environmental performance
indicators, and develop ob-
jectives and targets.
ST Microelectronic, Inc.
Discussion
Respondents cited at least 12 critical fac-
tors for successful implementation of an
environmental management system.
1.	Leadership: active support by top
management (namely the CEO
and the Production Manager).
2.	Workforce education, involvement,
concept buy-in.
3.	Incentives: connecting outcomes to
compensation plans.
4.	Promotion: selling the benefits.
5.	Broadcasting success.
6.	The Quality Link: good measure-
ment, objectives, review, and
follow up.
7.	Resources: people, capital and
time allocation.
8.	User friendly systems.
9.	Consistency: aligning objectives
with desired outcomes up and
down the organization.
10.	Total involvement: input from
every section of the organization
during EMS design.
11.	Emphasize elimination of redun-
dancies; use existing systems.
12.	A true desire for performance im-
provement.
In short, the critical success factors are
leadership, training, empowerment, and
enthusiasm.
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24. Are there any specific financial drivers that influenced your decision to
adopt an environmental management system?
Findings
Yes
39%® ) No
Key Point
Three in five respondents said
that there was no specific
financial driver behind the
decision to adopt an environ-
mental management system.
Notable Quotes
There were no specific finan-
cial drivers, but the company
is always interested in low-
ering its cost of goods; envi-
ronmental management sys-
tems offer many opportuni-
ties.
Allergan, Inc.
No specific financial drivers.
We anticipated early on that
we might have to "do ISO
14001" because customers
wanted it, however this did
not occur (with a few excep-
tions). In certain geographic
markets the EMS, specifically
ability to register to ISO
14001, does affect our ability
to do business.
Hewlett-Packard Company
Discussion
Two in five respondents said that specific
financial drivers influenced their decision
to adopt an EMS. Three in five do not be-
lieve there was a financial driver behind
the decision.
Financial drivers mentioned by the re-
spondents include the desire to accom-
plish the following objectives.
>	Lower cost of chemical purchases.
>	Prepare for increased EPA en-
forcement expected in their indus-
try as a result of energy utility de-
regulation.
>	Reduce liability for the company,
its directors and officers.
>	Better manage major cost areas
(energy consumption, training).
>	Avoid citizen lawsuits.
>	Get the same benefits from an EMS
that they see others getting.
>	Reduce risk.
One respondent noted a specific financial
driver. Their company received a signifi-
cant tax break in exchange for locating in
a certain community. One of the condi-
tions imposed on the company was that it
deploy and maintain an "exemplary" envi-
ronmental management program. The tax
break resulted in a certain financial ad-
vantage to the company for locating in the
community that exceeded the cost of de-
ploying and maintaining their environ-
mental program.
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25. Are there any specific environmental drivers that influenced your deci-
sion to adopt an environmental management system?
Findings
Yes
33%'
0
No
67%
Key Point
Two thirds of the respondents
said there was no specific
environmental driver behind
their decision to adopt an
environmental management
system.
Notable Quote
An EMS gives you better con-
trol of the EHEtS function and
overall compliance. Under the
EMS, everybody will better
understand the EHEtS mission
Currently EH&S is "taboo" for
most employees). People tend
to shy away from EH&S in
most companies because they
do not understand its func-
tion. People love getting in-
formation. Our new EMS,
which is in development, will
get them involved.
Skyway Freight Systems
There are many young people
in the electronics industry.
They respond to increased
emphasis by the company on
environmental responsibility.
It increases their job satisfac-
tion.
Quantum Corporation
Discussion
One third of respondents said that there
was a specific environmental driver that
influenced their decision to adopt an envi-
ronmental management system. Environ-
mental drivers mentioned by the respon-
dents are listed below.
>	Risk reduction.
>	Litigation avoidance.
>	Environmental cost control.
>	Better manage environmental re-
quirements.
>	Image enhancement.
>	Good neighbor policy.
>	Win environmental business
awards.
>	Commitment to environmental ex-
cellence.
>	No specific environmental driver,
"just issues we care about."
Two thirds of the respondents said there
was no specific environmental driver.
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if '
Discussions with Industry
About Environmental Management
26. On a one-to-ten scale with ten being "expert" level, how familiar are
you with the ISO 14000 standards?
Findings
Key Point
Seventy-five percent of the
survey population lies in the
top half of the "Level-of-
Expertise" range. All respon-
dents have environmental job
responsibilities for their
companies.
This confirms that the survey
population was generally
qualified to opine on the
relative merits of standards-
based environmental man-
agement systems.
Discussion
Respondents ranked their ISO 14000
knowledge on a 1 to 10 scale as shown on
the chart below.
Respondent Self-Rating on ISO 14000

J3_
1 i 2 I H " I 5 I 6 I ^
~ Number of
0
° j 5 | 2
1 | 3 I 4
11
Respondents

I ;
! I

Knowledge Rating (1-Lo to 10-Hi)
Dividing the self-ranking results into
"Higher" and "Lower" knowledge groups,
over 75 percent of respondents rate their
knowledge of ISO 14000 at 6 or greater
Thus three-fourths of the survey popula-
tion lies in the top half of the range.
This result provides an informal but useful
confirmation that the majority respon-
dents are knowledgeable about environ-
mental management systems in general
and ISO 14000 in particular.
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il0ar&	Discussions with Industry
About Environmental Management
27. What factors influence the decision to become registered to an interna-
tional standard like ISO 14001?
Findings
Notable Quotes
Unless you have some kind of
registration or certification, you
can't tell customers anything
[believable]. We asked ourselves
"How would we respond if our
biggest competitor started tell-
ing our customers that they now
"conform" [self-declare] to the
ISO 14001 standard?"
Our answer was: "So what?"
Then we asked ourselves: Would
customers care if we told them
we were in conformance (but not
registered) to ISO 14001?" Our
answer to ourselves was "no."
We concluded that you could
only get respect if you are regis-
tered to the standard, so now
nine of our sites are registered.
Baxter International, Inc.
Brazil has gone "ISO 14000 nuts."
BHP World Minerals
The ISO 14001 standard is fun-
damentally flawed. It should
require substantial compliance
with laws and regulations. Under
EMAS, registrars contact regula-
tory agencies about the compli-
ance status of the EMAS-
applicant. This has not proved to
be a problem. By requiring sub-
stantial compliance in order to
earn the EMAS registration a
company is forced to focus on
root causes. If they can't sub-
stantially comply with legal and
regulatory requirements, they
don't deserve to be registered.
Allergan, Inc.
Discussion
Respondents mentioned the following fac-
tors that influence the decision to become
registered to a recognized environmental
management systems standard, as op-
posed to simply declaring conformance to
the standard.
> Geographic market
and requirements.
expectations
>	To provide additional levels of trust
among suppliers and customers.
>	Hoping for a competitive advan-
tage.
>	To improve compliance. Company
anticipates a regulatory mandate
for ISO 14001 registration or strong
encouragement to do so.
>	Desire for third party (registrar)
approval and associated image en-
hancement.
>	To lend credibility to the com-
pany's environmental claims.
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w
Discussions with Industry
About Environmental Management
28. Does your company intend to become (or is it) registered to ISO 14001
or to any other standard?
Findings
42%#^) No
58%
Key Point
Many respondents who an-
swered "No" to this question
said that they are "closely
evaluating" ISO 14000. A
count of those responses,
when added to the group that
does intend to or is already
registered, is that up to
three-quarters of the respon-
dents may register to ISO
14001 in the next few years.
Notable Quote
Yes, but not all facilities will
be registered. The facility
must serve a global market.
Allergan, Inc.
One site in Kansas City is ISO
14001 registered because of
its DOD / DOE involvement.
Allied-Signal Aerospace
Yes. Closely evaluating regis-
tration and will probably do
it in January 1999.
Alta Plating and Chemical
Corporation
Discussion
Forty two percent of respondents are con-
sidering registration to ISO 14001, or are
already registered. The remainder has not
made that decision. Many said they are
"closely evaluating" ISO 14000. Some said
that ISO 14001 was not a cost-effective
approach for their company, but that
situation could change.
Adding the 10 companies reportedly
"closely evaluating" ISO 14001 to those
that responded "yes" to this question, the
"yes" percentage jumps from 42 percent to
73 percent.
One possible conclusion to draw from that
observation is that: up to three-quarters
of the respondents may register to ISO
14001 within the next few years.
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