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Historically, environmental management in corporations and small companies alike has not been included in the “inner circle” of senior management. Many organizations placed environmental management on the back burner until compliance issues arose or contamination was found on the property. When those instances occurred, senior management suddenly gained an intense interest in the subject.

Today, many organizations are beginning to think beyond environmental compliance towards environmental performance. Vital information about the compliance status of a company, how many pounds are emitted or who is responsible, can easily be accessed over the Internet. This leads to an unprecedented awareness by the public of whether an organization has a positive or negative impact on the environment. Those who are responsible for the bottom line of a company are also beginning to recognize that a well-designed Environmental Management System (EMS) can have a profound impact on a company. This impact not only extends to the short-term bottom line and public image, but also to the long-term financial health of a company. At this time an EMS that has been certified to the internationally recognized International Organization of Standards (ISO) 14001 Standard is considered the state of the art in environmental management.

The definition of what actually constitutes an EMS can be somewhat ambiguous. The ISO Standard itself establishes broad specifications as to what an EMS must contain, but there is a tremendous amount of flexibility designed into the Standard in order for it to be applied on a global basis. A wide range of applicable regulations, customs and technological capability are found throughout the approximately 100 ISO member nations. Taking this diversity into account the Standard requires this inherent flexibility. Simply described, an EMS is a collection of environmental operating procedures that are linked together into a collective system. In its most simple form, an EMS is the vehicle that pulls together all of the existing programs you may have for environmental compliance, training, record keeping and inspections into one organized system. To these existing systems, which are typical in-place for regulatory compliance purposes, an internal audit & corrective action system would typically be added, as well as goals to reduce environmental impact and improve performance.

Many common motivating factors spurn companies to put forth the effort needed to develop an EMS. Certainly, response to customer “questionnaires” about the status of your EMS is a great motivating factor. Organizations are also beginning to realize that developing an EMS can eventually streamline their environmental management effort, and in the process enhance their public image. It turns out that dollars saved by implementation of an EMS can be coupled with the enhanced market advantage ISO affords. Organizations have begun to realize not only the potential environmental efficiency gained by such a program but also the favorable public relations image being “green” can afford. This image can serve to help differentiate these companies from their competitors.

What are the essential elements that comprise an EMS? In order to be successful, an environmental program should have the support of senior management. Usually, this support is made tangible through a written policy or vision statement that summarizes the key points and is signed by the organization’s president or other senior official. Without that visible support, and the behind the scenes conviction to do what is required by regulation and dictated by common sense, the EMS will fail. Those organizations that are viewed as world class often have Chief Executive Officers who vocalize their commitment to environmental excellence.

The second component of an EMS is to have a thorough understanding of exactly what environmental requirements apply to an organization and what their status is in terms of conformance. The EMS is structured to help the organization meet its commitment to conform with these legal and other environmental requirements. The ISO Standard does not require that a company to be in complete compliance with regulations but rather that the policy statement makes a commitment to comply with relevant regulations. The purpose of the EMS is to create systems that help ensure compliance and continually improve environmental performance by understanding and reducing the impact the organization has on the environment. This has implications that go far beyond the reach of regulatory compliance issues. It is this thinking outside of the regulatory box that creates opportunities to reduce operating costs, decrease future liabilities, enhance the image of the organization and truly improve performance.

In order to move beyond compliance, the ISO Standard requires that an organization examine the aspects of its’ operation that it can control and their impact on the environment. Aspects are far reaching in definition and can be the manufacturing processes of an organization, the supporting functions, manufactured products, or the services they provide. When considering these processes, it is a common occurrence that not much thought is given to events that occur outside of the immediate area. Examples of impacts that are not readily apparent are the energy used to supply the process, the environmental issues surrounding the raw materials input, and related transportation issues in delivering product or materials. All of these areas have an indirect impact on the environment in addition to the obvious. The approach to environmental impacts needs to encompass a mind-set that considers all of the potential impacts that can be controlled by the organization. Keep in mind that most activities that surround a business have some impact on the environment, from employees commuting to work, using and recycling paper, to the landscaping of the property.

Our experience as consultants in developing successful systems for various industries leads us to believe that the determination of aspects and impacts becomes the heart of the EMS. Many of the subsequent components of the EMS will stem from the aspects and impacts an organization may have. The interconnection or linkage of these components is key to both the successful implementation of the plan and its ability to become self-sustaining.

The question then becomes how does an organization begin a thorough examination of the aspects and impacts of its operation. To begin this analysis, an organization should decide the scope of what they plan to include in their EMS. If just the manufacturing processes and their impacts are considered, other opportunities for improvement may be overlooked. Aspects and impacts should be examined for both the frequency of their occurrence and the severity of their impact on the environment.

With the proper planning given to the ranking scheme, it will become apparent which of the impacts your organization has have the greatest or “significant” impact on the environment. These become the focal point of the EMS, rather than the wide myriad of environmental impacts that abound in most organizations. Areas identified as significant may have already been given a great deal of emphasis by your organization. The emphasis may not have been strictly environmental but rather the activities were somehow deemed to be of such a critical nature to the success of the operation to warrant this level of effort. For example, it is commonplace that supporting operations such as heating, ventilation and cooling systems that are deemed to be critical to the process are well maintained. Any failure of these systems could lead to process shutdowns with their accompanying negative ramifications to the operating costs of the business. When the environmental impact of these operations are brought into the equation, an added emphasis to increase the efficiency of the system and reduce waste is brought to the forefront. The combination of these two driving factors to maintain systems at peak efficiency will serve to increase consciousness of their relative importance. Standard Operating Procedures and inspection protocols can be developed when dictated by the list of significant impacts. The systematic ability to control paperwork can help to ensure that these critical tasks are performed on schedule thereby leading to a streamlined management of these activities.

In the ISO EMS system a subsequent area of environmental management that is linked to significant impacts are objectives and targets. Objectives are broad-based goals an organization will establish based on those significant impacts that can feasibly be improved. This feasibility works within the economic reality of the financial resources of the organization. The targets are the specific metrics associated with the objectives. The objectives and targets are one of the methods whereby an organization will demonstrate a drive towards continual improvement in reducing the impact it has on the environment.

Another method of moving toward continual improvement that should be integral to every EMS is a corrective action system. Deficiencies that are discovered during internal management system or compliance audits can be addressed by the corrective action process. Typically, corrective action formats have a provision to escalate up the chain of command to ensure they are taken seriously. The other essential element of a corrective action system is an analysis of the root cause of the problem. Experience tells us that just correcting an audit finding will almost guarantee that this issue will be repeated sometime in the future. Rather if the root cause of this problem were identified, then the problem will more likely be permanently addressed. The effort spent in attempting to discern the root cause of a problem will pay dividends in minimizing the risk of repeating the issue.

Perhaps one of the problems with environmental management in the past is that it saw itself outside of normal business functions and had to struggle for funding and recognition. Too often, much of what went on in the environmental department was veiled in secrecy for fear that discussing environmental issues publicly could lead to disclosure of some compliance issue tipping off the regulators. This “head in the sand” or ostrich approach directly contributed to the lack of recognition that many environmental departments suffered from. In fact, many public interest groups have been able to capitalize on this weakness by utilizing readily available information contained in reports submitted to regulatory agencies. The ISO model for an EMS requires that the environmental policy of the organization be made readily available to the public or any interested party. In addition, the people who work for the organization should be aware of the program and such issues as the goals and objectives. Today many forward thinking companies are discussing their successes (and failures) on company web-sites, in public forums and at company communication meetings. This direct involvement by the environmental management staff will go a long way towards alleviating some of the lack of communication that was prevalent in the past.

Companies that have made an honest effort at compliance to regulations already have a leg up in developing their EMS. If they couple this effort with the tools they routinely use to manage their business, they will find that much of the framework for the EMS already exists. The ISO 14001 Standard provides an internationally accepted model that has an inherent amount of flexibility designed into it. Companies that have already developed an ISO 9001 Quality Management System can choose to readily adapt such existing systems as document management, internal system auditing and corrective action to their EMS. The emphasis in developing an EMS should be to integrate systems that have a proven track record and are known to work.

Most of the concepts discussed are essentially part of what business management has evolved to become in the late 20th century. The concept of continual improvement or the reduction of the negative impact an organization has upon the environment is the cornerstone of an EMS. The management of environmental affairs should be elevated to the same level as any business issue. It should also be held accountable to the same criteria as any other parameter. Business owners and senior management should expect improved performance from their environmental department just as they would from quality and the efficiency of their manufacturing processes. Over time, the initial level of effort made to pull together an EMS will be justified by the streamlined management of environmental issues and the measurable gains in performance.

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