Leveraging Your NSF Certification: Now that you've received NSF Certification ... why not leverage the Mark to your advantage.
Registering to ISO 14001 doesn't mean you're forever green. If you want an EMS to keep moving your organization forward to improved environmental and business performance, you need to maintain and refine it. The first step toward doing so is understanding the stages that each EMS goes through on its way to full business integration.
Most organizations have probably not yet considered the topic of maintaining their environmental management system (EMS). Many are just now becoming familiar with the concept of an EMS - a trend that has seen a large upswing with announcements by Ford, GM, Honda, and other large companies encouraging their suppliers to have an ISO 14001-based EMS. Other companies are in the throes of EMS implementation.
The maintenance of what has yet to be fully developed is generally the furthest thing from the mind of the EMS Representative. (For purposes of this article, "EMS Representative" means the person or persons charged by top management with responsibility for establishing, implementing, and maintaining the EMS per section 4.4.1 of the ISO 14001 standard.) Even organizations that have successfully registered or self-declared conformance to the ISO 14001 standard often do not give careful thought to how their new EMS will be maintained over time.
Maintaining your EMS does not mean keeping it the same over time. It means planning for the maturation of the EMS so that it continues to provide value. After all, business is business and if the perceived value is little or none, the topic of EMS maintenance becomes academic.
The framed registration certificate in the lobby often lends a false sense of security, suggesting that the EMS is, by virtue of registration alone, providing all the value it possibly can for the organization. What do you think registration really means to your company?
If you agreed with any of the above statements, read on. Carefully.
Registration means that your organization can claim it has a documented EMS that meets the ISO 14001 standard requirements, is fully implemented, and is consistently followed. It does not mean that you are necessarily a superior environmental performer. Under ISO 14001, your organization itself determines (through your objectives and targets) the levels of environmental performance it intends to reach.
In this article, I hope to dispel the notion that an EMS (even a registered EMS) will automatically provide value to your organization over time or be worth your investment. It all depends on how your EMS is implemented and maintained.
Take a minute to test your understanding of EMS maintenance. Circle T for true or F for false for each of the following statements:
| T or F | Our organization is certified and that's enough for us. We don't really need to do anything else to maintain our EMS. |
| T or F | Our certification means our EMS is effective. |
| T or F | We conform to ISO 14001 requirements; therefore, we have a good EMS. |
| T or F | The system will maintain itself. |
How many of these statements reflect attitudes within your organization?
As you will see from this article and a follow-up piece entitled "Maintaining Your EMS: Six Critical Control Points", none of these statements is true.
If people and processes in your organization changed little over the years, the issue of maintaining your EMS would not be so critical. However, in a society where the planned obsolescence of technology can be as little as three months, rapid change is certain.
Even if your products or services do not turn over that quickly, at some point all organizations will experience changes in personnel, management, and organization; they will face new priorities, new processes, and budget constraints/resource limitations. Increasingly, organizations also confront change in the form of mergers/acquisitions and downsizing. An EMS that is effectively maintained will help your organization manage the direction of these changes as they affect your liability, risk, public image, and environmental performance.
The first step in planning for EMS maintenance is to recognize and understand the major stages an EMS will typically move through over time. For simplicity's sake, EMS maturation is presented in three stages (see Exhibit 1):
Exhibit 1 summarizes five attributes for each of the three stages of EMS development. These attributes are Timeline, Goals, Activities, Characteristics, and Vulnerabilities. Each is discussed briefly below.
With an understanding of these stages of EMS development, your company can determine the rate at which your EMS is maturing and ascertain whether the EMS is structured to give management the desired results.
The three stages of EMS progression are discussed in more detail below using selected highlights from the Goals, Activities, Characteristics, and Vulnerabilities shown in Exhibit 1. Since the timeline for each stage is self explanatory, and a discussion of it can be found above, the timeline is not included in each stage description.
Whether a company takes six months or two years to work through the beginning stage, the attributes described below remain the same.
Goals: EMS implementation is often a mandate from upper management, and comes with a timeframe, such as: "Have registration/conformance completed by June 2001." The underlying message is, "Develop an EMS, but don't change anything." In an effort to develop an EMS as cheaply and expeditiously as possible, companies frequently start out with relatively modest environmental objectives such as recycling office paper. This approach is often successful and saves the company money in the beginning stage thanks to previously overlooked opportunities in pollution prevention or waste management. The idea of taking a hard look at process lines or chemical usage as areas of possible environmental improvement typically is not considered at this stage.
While there is nothing wrong with recycling of office paper as an environmental objective in the beginning phase, the "don't change anything" attitude should not become the unspoken modus operandi for the entire future of the EMS. If goals are not modified once implementation is complete, the EMS will not mature beyond the beginning level.
Activities: The biggest challenge organizations face in implementing ISO 14001 is moving away from a compliance-based approach to a more comprehensive systems approach to environmental management. This is true even for large companies that have had media-based compliance programs in place for years (e.g., hazardous waste and wastewater programs).
Training needs usually encompass various levels within the organization, from management to line workers. The challenge the EMS Representative faces is tailoring the EMS message to the audience and ensuring that it is understood. Management must carefully consider (often for the first time) what, if any, information regarding environmental issues it is willing to disclose to the public.
Characteristics: Many companies form cross-functional teams to assist the EMS Representative with implementation. Often, however, use of the team is limited to aspects/impacts identification and objective/target determination. Many of the tasks of implementation are not delegated, but instead are assumed by the EMS Representative. As a result, most of the resident knowledge about the EMS is held by one person.
Companies developing an EMS usually do so under a tight deadline for registration or declaration of conformance. As with any project where a deadline has to be met, EMS development is focused and energy-intensive. In order to launch the EMS, management openly expresses support for it in an environmental policy, in training, and in providing resources (usually in the form of assigning a person or team responsible for implementing standard requirements). However, upper management typically wants a minimal investment in the EMS beyond employee time, and has little involvement in the planning phase of the EMS.
Developing metrics, even simple ones, to track the process of environmental objectives and targets can be a challenge for companies because their process measurements or accounting structures often have not been set up to measure environmental parameters or costs.
Vulnerabilities: An organization may meet the requirements of each of the 17 elements of the ISO 14001 standard and yet not fully recognize the interactions of those elements, even though such an understanding is a fundamental concept of the systems approach. For example, let's say that a process line is scheduled to be transferred to another facility. Are elements of the EMS interwoven so that all possible resultant changes to the EMS procedures and processes would be evaluated?
The deploying stage is a transitional phase. While this stage represents the real growth of your EMS, it is also the most vulnerable time. How your EMS is managed at this stage will determine whether it provides value to your company and continues to mature, or instead slowly declines over time.
Management will, at least initially, view an EMS as another project with a deadline. It is tempting for management to see registration/conformance as the ultimate goal of the EMS, after which the EMS can run itself. The truth is that registration/conformance is really just the beginning of EMS development. At the time of registration, a company's EMS is fully implemented, but typically very immature and untested. After registration comes the hard part: improving the EMS while maintaining it through personnel changes, process changes, organizational changes, new initiatives, and competing management priorities.
Goals: An important goal for this stage of the EMS is to develop metrics that clearly demonstrate the benefit of the EMS and how it supports the attainment of larger business aims. During the beginning stage, the goal is clear: develop the EMS and register/conform by a certain date. Once this step is accomplished, however, other business priorities will take center stage. The EMS Representative must be able to demonstrate the value of the EMS if it is to continue to enjoy management support and resources.
Another critical goal of the deploying stage is strengthening the interactions among EMS elements. Some of these linkages are relatively easy to recognize. For example, most organizations realize that EMS audit results provide input to management review. However, what elements of the EMS may be affected when a customer places an order for a new part that would result in the generation of a hazardous waste at your facility? Is your system structured automatically to consider all of the pertinent elements of the EMS in these day-to-day operational decisions?
Activities: This stage typically involves integrating the EMS with the organization's existing management systems. Some integration with the quality management system often occurs during the beginning stage (common areas include document control, records, and training). However, it is difficult to implement a new system and achieve full integration at the same time. The more complex the organization, the more integration will be primarily an activity of the deploying stage. As linkages between the EMS and existing practices are recognized, integration of the EMS will continue into areas such as health and safety, resource allocation, operational controls, information and support systems, training and development, accountability structures, and communication and reporting. A side benefit of this continued alignment and integration is that the EMS will move away from being dependent on one person (the EMS Representative) for its daily operation.
Characteristics: An EMS in the deploying stage could be described as experiencing "growing pains." Many companies registering to ISO 14001 have all the basic requirements in place, but their system has not been tested over time. Even with strengthening linkages within the EMS, one element tends to remain weak: corrective and preventive action. This weakness generally stems from devoting little effort to prevention and from failing to recognize all the organization's potential sources of nonconformance with the EMS. The follow-up to this article, "Maintaining Your EMS: Six Critical Control Points," will discuss the importance of corrective and preventive action in detail and will provide a model for improvement.
An EMS successfully progressing through the deploying stage will be the driving force for changing the organization's perception of its environmental function from overhead technical support to a cost-saving center integral to the company's overall business strategy. An EMS in the early deploying stage is rarely linked to corporate planning, goals, or decision making; instead, the EMS is consulted after the fact. Typically, for example, a facility in the early deploying stage will decide to begin making a new product without discussing it with the EMS Representative. The plant manager will then simply inform the EMS Representative that the new product is to be manufactured at the facility, and will direct the Representative to determine how the EMS will be affected. With a more mature EMS, the plant manager will involve the EMS Representative in the up-front decision on whether or not to accept the new order.
Resistance to EMS-related changes is often seen in the areas of documenting procedures, tracking targets, and training. Changing the culture of an organization requires time, consistency in approach, management support, and demonstrated success - but it can be accomplished. Without this cultural change, the EMS cannot become established as a business practice.
Vulnerabilities: Objectives and targets initially developed for an EMS are often aimed at "low-hanging fruit" such as paper and scrap recycling. This is perhaps appropriate in the early stage of the EMS. However, if this approach continues throughout the deploying stage, more challenging interactions with the environment (such as chemical usage, process waste, or resource use) may be overlooked. Without "stretch" objectives and targets, the EMS will not progress.
Maturing: EMS as a Business Practice
An EMS will move into the maturing stage only after successfully negotiating the transition phase. The key to maturing an EMS is that it must continue to demonstrate value to the organization. For most organizations, this means cost savings. For others, it could mean increased market share, reduced liability, an improved rating on the Dow Jones Sustainability Group Index, decreased public criticism, or any combination of reasons. Note that attaining registration alone, even if it is a customer requirement, will not be enough to demonstrate value as time marches on. As will be discussed in the follow-up to this article, defining success for your company's EMS in the beginning stage, and then updating that definition periodically, is the best single step you can take to ensure that the EMS continues to mature.
Goals: One goal of an EMS in the maturing stage should be actively seeking to determine stakeholder needs and meet them. Organizations at this level see value in being more open with the public about their environmental issues, and actively use the EMS to address public concerns. The public may even be involved in determining environmental objectives. Companies at the maturing stage typically have sustained high levels of environmental performance and are proud to communicate this to stakeholders. Other stakeholder needs may include participating in regulatory or industry initiatives and local community involvement.
Activities: At the maturing stage, the EMS is part of the company culture at every relevant function and level of the organization, and this is reflected in where EMS resources are expended. Improved efficiency through process improvement is a primary activity. For example, it is common for a deploying EMS to experience a documentation boom. A maturing EMS recognizes that "less is more" and works to streamline processes. A key activity of the EMS at the maturing stage is its involvement in business decisions. This includes daily functions such as engineering and production, as well as periodic strategic planning.
Characteristics: Characteristics of an EMS in the maturing stage include:
One often overlooked advantage of a mature EMS is that it serves as a launch pad for new environmental initiatives. For example, a major customer may ask for a life cycle analysis of costs, or management may decide that environmental labeling would provide a competitive advantage. An EMS will provide the structure and data to develop these new strategies with little if any additional investment.
Vulnerabilities: Any system, no matter how well established, must be able to demonstrate its value to management, particularly when budgets are cut, reorganization or reassignment occurs, or new businesses are acquired. Strategies for countering the vulnerability of a mature EMS include developing meaningful metrics as your business changes, demonstrating a history of cost savings, and aligning EMS goals with overall business goals.
Putting Your EMS in Perspective
An EMS, even a registered EMS, will not automatically provide value to your organization over time. It all depends on whether your organization has a plan for moving the EMS forward. The EMS Representative must be able to answer the question, "What does the EMS need to do in order to demonstrate value to management?" and then establish goals which will support that answer.
The first step in planning for long-term EMS survival is to recognize that an EMS moves through predictable stages over time: beginning (EMS under development), deploying (EMS registered/in conformance), and maturing (EMS as a business practice). With an understanding of these stages of EMS development, your company can gauge the rate of its EMS development and determine whether the EMS is structured to give management the desired results.
It is important to keep the role of an EMS in perspective. While an EMS is no guarantee of a successful company, it is hard to imagine a company achieving success in the new millennium without a value-creating EMS.
S. Petie Davis has served as an environmental consultant, manager, and auditor for the past 15 years. She is a Senior Program Manager and Lead Auditor with NSF-International Strategic Registrations, a registrar for ISO 14001/9000. She invites reader perspectives and comments on this article. Ms. Davis can be reached at davis@nsf.org or at 734-827-6810.
New environmental management standards, such as ISO 14001 and EMAS, will help provide platforms from which companies can reach for the relevant stretch goals.
But they will not of themselves ensure that companies make sufficient progress in the right direction.
Instead, the experience of successful companies suggests that the magic ingredient is a combination of strategic clarity, hard work, and new alliances.
– John Elkington, Cannibals with Forks