By Russell V. Thornton

The ISO 14000 series of environmental system standards, sometimes referred to as the "green" standards, establishes specific requirements for developing comprehensive environmental management systems. Formalized by the International Organization for Standardization on Sept. 1, 1996, the standard was developed to give organizations a structured framework with which to formulate policies and objectives for environmental management systems (EMS) while simultaneously considering legislative requirements, relevant public issues and plant-specific environmental concerns.

An EMS provides a systematic approach for controlling the environmental impacts of an organization’s activities and processes. The time for implementing an EMS is now, and companies are well-advised to initiate one as soon as possible. Skeptics who wonder whether it is necessary to go through the trouble of implementing an EMS should realize that the United States is not the main driver for ISO 14000, and it will not go away. In fact, ISO 14000 may be the ticket to trade in Europe and Asia.

Evidence from various international initiatives indicates that ISO 14001 (EMS specifications with guidance for use) will be widely adopted. Registrations are underway in the United Kingdom, Japan, East Asia, Brazil, India, Korea, Argentina, Hong Kong, and Taiwan. The Japanese Ministry of International Trade and Industry advocates mandatory third-party ISO 14001 registrations, and the Japanese electronics industry has responded by developing the necessary infrastructure to comply. Many U.S. companies are reviewing their existing environmental programs against ISO 14001 criteria to develop implementation strategies.

Companies considering the ISO 14001 registration process first must understand the benefits of becoming certified to the worldwide standard. Registration increases the visibility and credibility of a company’s environmental management processes, especially in the eyes of environmental regulators. Registration also may enhance marketing and public relations efforts and improve a company’s relationships with nongovernment organizations and customers. But mot importantly, ISO registration offers a company an objective evaluation that can be used to improve the effectiveness of its EMS.

Once a company understands why ISO registration is important, it is ready to map out a strategic approach to achieving registration. The approach will depend on whether more than one site is involved, whether the company will seek multisite registration or individual registration for each facility, and to what degree it plans to integrate the EMS with its safety, health, and quality systems. The company should then draft a clear policy, including a commitment to continual environmental improvement; assess its most significant environmental aspects; develop objectives (broad goals to reduce environmental impacts) and targets (measurable, quantifiable statements about how to achieve objectives) to address the aspects; and establish programs and procedures to meet the goals. (ISO 14000 defines environmental aspects as "an element of an organization’s activities, products, and services, which can interact with the environment.")

Once a company has decided on a strategy, it should establish an environmental base line and develop a plan for building and implementing an EMS. EMS consultants can be helpful during this phase. Companies also should consider sending employees to training courses about management systems and the ISO 14001 standard.

For those unfamiliar with the standard, ISO 14001 specifies the following necessary components of an EMS:

• Defining an environmental policy
• Identifying legal obligations and environmental aspects
• Creating environmental planning objectives
• Establishing an environmental management program
• Specifying how to achieve objectives
• Implementing the EMS and operational controls
• Assessing conformity with the requirements of the standard and taking corrective actions in cases of non-conformity
• Conducting internal EMS audits, and
• Conducting a management review of the EMS.

Companies beginning the ISO 14001 registration process do not necessarily need to start from scratch, because many probably already have useful resources in their databases. Examples of existing resources that companies often overlook when developing an EMS include Occupational Safety and Health Act lists of chemicals used in the facility; hazardous operations reports; chemical substances inventories; process safety management documents, including Form R, Tier 1 and Tier 2 reports submitted under the Emergency Planning and Community Right-to-know Act; contingency or vulnerability studies about critical systems or equipment; risk management studies; corrective action reports; and maintenance records.

After gathering critical data about a facility, the company should examine the facility’s surroundings and ask such obvious questions as: Where is the plant located? Is it near a river or wildlife sanctuary? Is it within a nonattainment area for some air pollutant? Is it next to a school or in a major city? The data should be integrated and evaluated to:

• Determine whether the environmental actions related to the environmental aspects being considered are financially feasible and whether the organization has control over them (supplier or material issues often are beyond an organization’s control) and
• Identify reuse, disposal, and recycling options.

Companies must ascertain their degree of control over each and every environmental aspect, pinpoint potential regulatory issues, and evaluate technologies that could prevent or reduce environmental impacts. Environmental aspects identified during brainstorming sessions (which are most effective when knowledgeable people gather around a table instead of manipulating computer models on their own) should be addressed. A documented procedure addressing each aspect is unnecessary, but some method to control each significant aspect should be developed.

The completed environmental policy must be appropriate to both the nature and scale of a company’s activities, products, and services and include a commitment to continual improvement, pollution prevention, and compliance with environmental legislation and regulations. The policy must be documented, implemented, maintained, communicated to all employees, and made available to the public.

Registration and Accreditation

Once a company has developed and implemented (or is about to implement) an EMS, it should contact an accredited ISO 14001 registrar to begin the registration process. A registrar is an independent, third-party audit organization accredited or approved to conduct ISO 14001 registrations by a national accreditation body (which, in the United States, is the ANSI-RAB National Accreditation Program).

The methodology, or process, of registering a company’s EMS to ensure that it meets ISO 14001 requirements varies, but registrars generally follow a two-stage process.

First, a registrar visits a facility and conducts a review of the components of the EMS that must be documented under the standard. If the EMS seems ready for registration, the registrar conducts a registration audit, which is a comprehensive assessment of the EMS against all elements of the ISO 14001 standard.

If all goes well, the registrar recommends the company for registration and the two parties agree on a schedule for follow-up maintenance audits (which can be every 6 months, every 9 months, or yearly). Most registrars issue approved companies a 3-year registration certificate. When the certificate expires, the company can choose to reregister to the standard or withdraw its certificate.

The cost of registration and the amount of time it takes to conduct the registration audit varies by industry and company. Costs are based on the size of a company, the nature and complexity of its processes and activities, and the number and significance of the environmental aspects and impacts. The number of onsite audit days ranges from 3 to more than 10.

Typical EMS implementation should make use of existing procedures, programs, and systems whenever possible. A practical checklist might call for a company to:

• Implement team reviews to determine standard requirements
• Identify ISO 14001 "process owners" at the site
• Identify all sites, processes, and functions with special requirements applicable to the EMS
• Define and document a matrix of existing policies and procedures
• Develop additional procedures if they are needed to meet requirements
• Develop internal training materials and instruction methods
• Train internal auditors and relevant personnel in ISO 14001
• Develop communication methods, such as a newsletter, to promote ISO 14001 to facility employees
• Implement all new or modified procedures and document evidence of implementation in an internal EMS audit
• Rectify nonconformities, and
• Plan the registration audit by writing a statement of scope and registration strategy.

Registrars use a checklist linked to the standard when determining whether an EMS meets registration criteria. Therefore, it is imperative that companies also create and use a checklist when planning their implementation and registration. Following these steps will simplify the process of developing an EMS. Above all, companies must remember to be practical, keep procedures simple, and not waste time addressing issues over which the organization has no control.