Expansion of Environmental Management Systems to Address Sustainability

ART GILLEN First Environment, Inc.

At the very basic level, a management system provides a structure that allows an organization to systematically manage a particular issue by:

• Defining, assessing and understanding the issue within its boundaries;

• Planning and implementing controls and improvements; and

• Monitoring and evaluating performance of associated efforts.

These functions of a management system are reflected by specific processes, procedures, and tools necessary to manage the relevant issues.

4.3.1.1 Broadening the Scope of the EMS. Each particular management system design identifies key system elements as well as provides a focus important to addressing the management issue. Expanding management systems to address sus-tainability, in general, involves expanding the focus of the system, using a balanced approach, to include environmental, social and economic impacts and influence of the organization.

A key consideration regarding this expansion of environmental management systems is to recognize that the basic arrangement and the operation of the system does not considerably change. The scope of the management system is simply expanded to include issues, topics, ideas, and concepts representing social and economic concerns. For example, in addition to employee health and safety, the system could consider employee education programs. In addition to coordination of solid waste disposal services, an expanded management system could address community health care services. Or instead of driving hazardous waste reduction, a sustainability-expanded environmental management system could increase employee diversity.

Environmental management systems have an advantage over many management systems with respect to expansion toward sustainability. Environmental management systems already address one of the components of sustainability. This aspect makes them a perfect starting point for further advancements.

4.3.1.2 Plan, Do, Check, Adjust. Most management systems have the common foundation of the plan, do, check, and adjust (PDCA) cycle, which drives the organization's continual improvement of its performance regarding the issue. This common foundation provides a basic process for advancing an organization with respect to the focus management issue. After these boundaries of the system are expanded, the stages and steps of the PDCA cycle can also be enlarged to address the broader focus required for a corporate sustainability program.

In the first step of the planning stage, the expansion of the management system's scope can be reflected through the identification of sustainability in the policy statement and specific commitments to social, environmental, and economics issues that comprise it. This change generally identifies management recognition and support of sustainability that can improve the program's success.

The planning stage of a management system also generally includes an assessment of activities and impacts of the organization. Although environmental management systems focus only on impacts to the environment, the assessment can be expanded to consider both social and economic impacts. These issues can include but are not limited to employee diversity, working conditions, wages and benefits, education and advancement opportunities, supply chain, philanthropy, and community development.

The planning stage also includes the identification of objectives and targets for the organization. These objectives and targets often include taking action on significant issues identified during the impact assessment. The introduction of social or economic objectives and targets provides the first steps for an organization to move beyond considering sustainability and working on the path toward it.

The doing stage of the PDCA cycle typically involves development of programs to achieve the objectives and targets identified during the planning stage. Many organizations develop sustainability programs independent of a management system. Developing sustainability processes procedures and programs within a management system, in addition to ensuring these efforts are aligned with articulated goals of the organization, also ensures that these activities remain under robust document control and record keeping common to all management systems.

The doing stage of the cycle also addresses roles and responsibilities within the system. Expansion of the management system to address sustainability may require the assignment of role and responsibilities to individuals whose activities were not primarily associated with the original system activities. These may include representatives from human resources, accounting, investor relations, or even marketing departments.

The check stage of the cycle involves monitoring and internal and external assessment of performance. Organizations can use this step to establish metrics that address social and economic issues, in addition to the environmental measures that they already use.

The check stage also involves assessment of the effectiveness of the efforts. This assessment can take many forms, from internal auditing to independent verification. These checking activities are important to sustainability programs in providing confirmation and improved credibility to efforts in social activities that often are difficult to quantify.

Perhaps most important to the effective function of a management system, the check stage involves a process for recognizing and formally identifying problematic issues or potential opportunities, as well as taking actions to develop solutions or obtain additional benefits. A robust environmental corrective action process should require little modification to be applied to social and economic concepts.

Finally, the adjust stage of the PDCA cycle returns an organization's activities, impacts, performance, and progress to review by organization management. Within a sustainability system, this stage ensures that environmental, social, and economic issues remain under ongoing consideration in the development of strategy, resource allocations, and major operational decisions.

4.3.1.3 Specific Strengths for Sustainability of Existing EMS Designs. Beyond the applicability and flexibility of a PDCA management system structure for corporate sustainability efforts, specific types of system designs also possess components that could be modified or enhanced to facilitate an organization's pursuit of sustain-ability. The subsequent contributions of this section provide overviews of the following existing management designs, whose focus is protection of human health and safety and the environment:

• The American Chemistry Council's Responsible Care Management System: This section introduces a management system that was customized to address the needs of the chemical industry.

• EMAS versus ISO 14001: This section addresses the additional aspects of the European Union's EMAS system, which builds upon the classic environmental management system structure of ISO 14001.

• Occupational Health and Safety Assessment Series: This section provides an overview of a management system design with a specific focus on human health and safety as compared to the broader scope of the environment.

• Six Sigma: This section covers using the quality management system and tools that assist organizations in implementing a process improvement methodology.

The strengths of each of these are as follows.

The ACC's Responsible Care Management Systems as well as EMAS systems include requirements for the public reporting of performance information. RCMS reportable metrics already include some economic measures for some organizations. Public reporting of performance information can increases transparency and facilitates stakeholder involvement. Organizations that use RCMS or an EMAS system can seek expansion to address sustainability by publicly reporting social and additional economic metrics and information.

RCMS includes requirements for community and stakeholder communications and outreach. While the basis of these communications and outreach under RCMS are typically environmental issues, an organization seeking expansion to sustainability could enlarge this program to address other issues of social and economic priority.

RCMS also requires third-party certification of any organization's efforts, which increases stakeholder confidence in reported information. This certification process can also be expanded to encompass a company's performance in social and economic areas.

EMAS requires more extensive involvement of employees in system operation and includes provisions regarding both suppliers and contractors. These aspects demonstrate important steps regarding stakeholder outreach. To expand the system to further support corporate sustainability, organizations with EMAS systems could include other stakeholders such as relevant government representatives, members of the communities in which they operate, their customers, in the operation of the management systems. This involvement would extend beyond external communication common to management systems and include participation in system operation such as the assessment of impacts, the setting of objectives and targets, or the development of sustainability programs.

Strengths of OHSAS 18001 include the system's component of proactive monitoring and measurement. This requirement could be more effective in addressing some social and economic issues that exist beyond the direct boundaries and control of an organization.

Six Sigma focuses on the integration of the human and process aspects of business improvement. By utilizing structured methods that link analytical tools into an overall program framework, there is now a standardized method for resolving work problems.

4.3.1.4 Summary. As presented in the following sections on various management systems, along with the basic PDCA structure, each of these management systems have strengths that can be leveraged to address the broader scope of sustainability's social, environmental and economic dimensions. In general, management systems provide a useful structure in which to develop sustainability programs. The conversion of an environmental management system to address sustainability involves expanding the focus of the system rather that significant modification. The stages and steps of the Plan, Do, Check, Adjust cycle can be expanded to effectively include social, environmental, and economic issues, which companies seek to address. Environmental management system designs, such as RCMS, EMAS, and OHSAS 18001, possess specialized requirements and components that can be further leveraged to more effectively pursue corporate sustainability.

4.3.2 The American Chemistry Council's Responsible Care® Management System

Art Gillen

First Environment, Inc.

The chemical industry's major trade association, the American Chemistry Council (ACC), has been implementing a program called Responsible Care® for over 15 years. This program is the industry's comprehensive initiative to address environmental, health, and safety (EHS), security, outreach, process safety and

"cradle to grave" product management. For more information about Responsible Care®, visit the ACC's web site at www.americanchemistry.com.

4.3.2.1 What is RCMS? RCMS is defined as a company's overall system to manage its Responsible Care® program. It replaces previous a Responsible Care® program that was based on meeting the 106 management practices of the initial six Codes. The Guiding Principles and management practices, including the seventh Code, Security are incorporated in the RCMS. As many ACC members plan to pursue ISO 14001 certification to meet customer or internal requirements or to further differentiate themselves from other stakeholders, a hybrid option of the RCMS, RC14001 was developed. As a result, there are two separate tracks for meeting the RCMS requirement, conformance with the RC14001 Technical Specification or the RCMS Technical Specification.

4.3.2.2 What is RC14001 Technical Standard? The RC14001 standard is based entirely on the ISO 14001 technical specification, including all 17 elements under the sections of Policy, Planning, Implementation and Operation, Checking and Corrective Action, and Management Review. It contains the whole of ISO 14001 with "boxes" under each element. These boxes describe additional Responsible Care® requirements. The technical specification is thus organized in a manner that allows for a company to receive an ISO 14001 only or an ISO 14001 and an RC14001 certificate.

4.3.2.3 What Are the Specific Additional Requirements in RC14001 above ISO 14001? These "boxes" of additional requirements differentiate RC14001 from ISO 14001. While there are a number of specifics, the boxed requirements fall into a few categories. They are:

• Health, safety and security;

• Community and stakeholder communications and outreach;

• Product stewardship;

• Transportation; and

• Commercial partner interactions.

4.3.2.4 RCMS Technical Specification. The RCMS standard is organized in the same manner, and contains mostly the same requirements. There are 30 elements divided into five sections: Policy and Leadership; Planning; Implementation, Operation and Accountability; Performance Measurement, Corrective and Preventive Action; and Management Review and Reporting.

4.3.2.5 So Why Two Specifications? The ACC Membership is very diverse in terms of the nature of their operations. They also have very different business needs. As a result, the association did not want to prescribe one specific method of certifying a company's Responsible Care® management system (i.e., ISO). The difference in the content of the standards, while minimal, includes terminology in the RCMS standard that more directly relates to the industry. For example, instead of using aspects and impacts and significance from ISO 14001, RCMS uses hazard, risk and prioritized. The most significant difference between the two specifications is the way each system is audited/certified.

Both RCMS technical specifications follow the Plan-Do-Check-Act framework after top management develops the organization's Responsible Care® Policy.

• Plan - Identify and evaluate environmental, health, safety, security, distribution, product, and process aspects and impacts, or hazards and risks. Establish goals, objectives, and targets and programs to meet them.

• Do - Establish roles, responsibilities, and accountabilities to implement the programs. Identify and provide necessary training, communication, documentation, and operational control.

• Check - Monitor and measure performance, investigate, correct and prevent nonconformances, including auditing the management system, and identify and maintain records.

• Act - Conduct a top management review of the management system to evaluate effectiveness and driving toward continual improvement.

4.3.2.6 ACC Certification Timeline. Regardless of which track is taken, ACC member companies are required to certify their Responsible Care® management systems. The Certification timeline is shown in Table 4.4.

4.3.3 EMAS versus ISO 14001

Rainer Ochsenkuehn

First Environment, Inc.

Environmental management systems (EMS), and also ISO 14001, are becoming household names in many organizations. But what about EMAS? Almost unknown in the United States, EMAS is the acronym for the European Eco-Management and Audit Scheme, a voluntary system based on European Union (EU) regulations and

TABLE 4.4. Certification timeline

Company

Minimum

1/2008-

size

required

12/2005

12/2007

12/2010

1-25 sites

33% + HQ

HQ audited

All required

Next cycle

(max of 4)

(minimum)

site audits

26 -40 sites

6 sites + HQ

HQ audited

All required

Next cycle

(minimum)

site audits

41+ sites

8 sites + HQ

HQ audited

All required

Next cycle

(minimum)

site audits

harmonized principles. The two systems are complementary, but EMAS is more rigorous in some areas. EMAS continues to be seen as more prestigious than ISO 14001 in many EU Member States. It is open to any organization in the public or private sector that is committed to improving its environmental performance. It is open to Member States of the European Union and the European Economic Area (Norway, Iceland, and Liechtenstein). An increasing number of candidate countries are also implementing the scheme in preparation for their accession to the EU. Originally issued as European Council Regulation #1836 in 1993, which allowed voluntary participation by industrial company sectors in the EMAS, this Regulation was replaced by (EC) N°761 /2001 OJ L 114 in 2001, which now allows participation in the scheme by all organizations.

New European Union environmental policies encourage the wider use of the EMAS logo (seen in Fig. 4.10) as a consumer-oriented tool to promote environmental improvements. Many organizations welcome such opportunities to make their environmental achievements more visible to stakeholders. Even the European Commission has committed itself to implement EMAS in its own services and buildings. As of July 2004, Germany had the most EMAS certifications, with over 2000 registered sites and additionally almost 1700 registered organizations (which included multiple sites). This is partly based on government/regulatory incentives, that is, grants for EMAS certifications, the increased environmental performance focus of EMAS, and also the historical emphasis of other countries within the European Union, such as the United Kingdom, to favor ISO 14001.

The objective of EMAS, similar to ISO 14001, is to ensure continuous improvements in environmental performance by getting companies and organizations to commit themselves to monitoring and improving their own environmental impacts (Fig. 4.11). The general aim of EMAS is to ensure that the European Community develops policies and implements actions to promote sustainable development and environmental issues. EMAS also covers the distribution of relevant information to the public. Independent auditors regularly check that participating companies and organizations fulfill their commitments, enabling them to keep their EMAS registration. ISO 14001 is a global standard created for corporate environmental management systems by the International Organization for Standardization (ISO). The main difference between the systems is that EMAS requires public reporting, while ISO 14001 does not. Furthermore, EMAS is considered a "stricter" regulation than ISO 14001, because the EMAS organization commits itself to the constant

Figure 4.10. EMAS logo.

EMAS

Figure 4.10. EMAS logo.

Verification

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