Will ISO 14001:2015 make a difference? A practitioner survey

Transcription

1 Will ISO 14001:2015 make a difference? A practitioner survey Introduction The revised ISO 14001:2015 standard for environmental management was released in September There are many new requirements and areas with increased emphasis, including considering how relevant internal and external issues may affect the organisation and its environmental management system; increased responsibilities for top management; determining environmental risks and opportunities; considering the environmental impacts associated with procurement and the life-cycle of products and services; and ensuring that environmental communications are reliable. In order to gauge the implications of these changes for organisations and whether or not they may lead to improved environmental performance, an in-depth survey was completed by ten organisations who are making the transition to from the 2004 to 2015 version of the standard. Participants were self-selecting, but they represented a range of industry sectors and sizes. This research was carried out by Marek Bidwell of Bidwell Management Systems and Kirsten McLaughlin of WSP Parsons Brinckerhoff with guidance from Dr Phil Longhurst of Cranfield University. Survey Questions Introductory questions were asked about the nature of each organisation and their environmental management systems. A summary of these results is presented in Figure 1. Participants were then asked to read a brief summary of each of the thirteen key changes in the 2015 version of the standard, before answering the following four questions about each change: 1. How relevant is this to your organisation? 2. How much change to your systems / procedures will be required? 3. Do you believe this will lead to environmental benefits / improvements? 4. Please provide a brief explanation of the scores you have given The replies to questions one to three had to be categorised by the participants into: High relevance / significant change / significant environmental benefit (Scored 4) Moderate relevance / moderate change / moderate environment benefit (Scored 3) Small relevance / small change / small environment benefit (Scored 2) No relevance / no change / no environment benefit (Scored 1) Don t know (Excluded from results) Page 1 of 14

2 ISO 9001? OHSAS 18001? Publish public report? Results Industrial sector Number of employees Year first certified Have one or more environmental permit? Attitude of organisation to environmental management? Professional services (1) Silicone release liners (2) Offshore oil & gas (3) Electronics (4) Metal products (5) Vehicle safety systems (6) Aerospace (7) Inspection services (8) Passenger transport exec. (9) Airport (10) 1, , , , Figure 1: Summary of respondents answers to introductory questions Yes Yes Yes Yes Moderately Yes Yes Slightly Yes Yes Yes Yes Highly No Moderately Yes Yes Yes Highly Yes Yes Highly Yes Yes Moderately Yes Yes Moderately Yes Yes Moderately Yes Yes Yes Yes Moderately The organisations participating represented a range of industry sectors from manufacturing to transportation. Four of the respondents had more than 1,000 employees, three between employees and three between The respondents were asked when they had first attained ISO The oil and gas company obtained ISO first in 1998, while the silicone liner manufacturer obtained ISO the most recently in Four of the organisations held the health and safety standard (OHSAS 18001) whilst nine held the quality management standard ISO These questions were asked because it was thought that the requirements of sister standards might help organisations to address some of the new requirements of ISO 14001:2015. All of the organisations held at least one environmental permit (for air, water, or waste) except for the electronics firm. Four of the organisations publish a publically available report that contains environmental information: Professional services, Oil and gas, Passenger transport executive and the Airport. This question was asked due to the increased requirements for planning communications under the new standard. Finally respondents were asked How would you describe the attitude of your organisation towards Environmental Management?. Three of the respondents reported that their organisation thought environmental management was highly, six moderately, and one slightly. Page 2 of 14

3 Figure 2: Ranking given by each respondent (1-10) to the question: How relevant is this to your organisation? The final column is the average ranking for the topic. Figure 3: Ranking given by each respondent (1-10) to the question: How much change in your systems / procedures will be required? The final column is the average ranking for the topic. Figure 4: Ranking given by each respondent (1-10) to the question: Do you believe this will lead to environmental benefits? The final column is the average ranking for the topic. Page 3 of 14

4 Topic-Based Discussions Each of the following sections contains an introduction to the new or changed requirement of ISO 14001, the results of how the survey participants ranked the change against three criteria, and a discussion of these rankings with particular reference to the written responses provided. 1.) Structure of Standard The clauses have been restructured around Annex SL framework for a generic management system. Instead of clause numbers 4.2 (Policy) through to 4.6 (Management Review) the new standard will have seven main sections: 4 (Context), 5 (Leadership), 6 (Planning), 7 (Support), 8 (Operation), 9 (Performance Evaluation), and 10 (Improvement). Typically, many organisations structure their Environmental Manual around the requirements of a standard, so it was hypothesized that this change will create some work restructuring this document. However, at the same time ISO 14001:2015 no longer contains a requirement for a documented environmental manual, so organisations may use this as an opportunity to reduce the complexity of their documented system. Relevance to the organisation: 11 th out of 13 Change required by the organisation: 4 th out of 13 Amount of environmental benefit: 5 th out of 13 The largely administrative benefit of this change was summed up by an organisation who develops and manufactures silicone release liners: The actual management systems for quality and environment are already interconnected, therefore slight relevance and small change. Benefit will come from more and better integration, auditing and maintenance of the systems. Furthermore a more uniform system will be the result also making it easier to implement other additional management systems following the same structure. 2.) Understanding the organisation and its context This is a new requirement to: determine external and internal issues that are relevant to the organisation s purpose. This means identifying internal and external issues that may affect the intended outcomes of its environmental management system, and also external environmental conditions that may affect, or be affected by the organisation. Once identified, these issues will inform the development of the environmental management system, including determining risks and opportunities. Page 4 of 14

5 Internal issues that may affect the success of the environmental management system (EMS) will be familiar to Environmental Managers. These may include conflicting organisational goals and policies, rapid change and limitations of human, technical and financial resources. External issues that may affect the outcomes of the EMS include changing regulations and regulators, new innovation and technology potentially leading to better pollution controls and economic factors (such as the last recession) that restricted investment and changed consumer behaviour. This clause also requires the organisation to consider how environmental conditions may affect the organisation (not just the EMS). This is a more strategic consideration and is linked to business planning and contingency planning. Examples include climate change risks such as flooding, disruption to global supply chains and soil erosion. Environmental changes may also create opportunities for some. Relevance to the organisation: 9 th out of 13 Change required by the organisation: 6 th out of 13 Amount of environmental benefit: 2 nd out of 13 These results show that respondents thought this change would lead to greater environmental benefit that most. Will need to expand the aspects register to include how the environment can impact the organisation. For example, climate adaptation, flooding, resource scarcity, population increase and increased extreme weather events says the professional services organisation. We are already aware of our context and the issues that can affect the EMS, including environmental conditions. But the additional focus on this in the EMS may have some added benefit in terms of enhancing management's awareness of how environmental conditions may affect the organisation, says the aerospace manufacturer who ranged this topic as highly relevant, but only requiring a small change. 3.) Understanding the needs and expectation of interested parties This new requirement requires an organisation to identify interested parties, determine their relevant needs and expectations and then determine which of these needs and expectations become compliance obligations. Once identified these needs and compliance obligations will inform the development of the environmental management system including the communications plan. Relevance to the organisation: 13 th out of 13 Change required by the organisation: 13 th out of 13 Amount of environmental benefit: 13 th out of 13 Page 5 of 14

6 It is perhaps surprising that stakeholder engagement was ranked the lowest in all three categories given the effect of bad publicity on organisations following environmental incidents in the last few years. However, all six participants who provided a written explanation said that their existing environmental management system already addressed interested parties, thus explaining the low ranking. For example the passenger transport executive said: We are currently undertaking stakeholder mapping for the organisation. We will need to formalise current relationships, and the aerospace manufacturer said: We already do this -- there is no conceptual difference from the previous concept of legal and other requirements to which the organisation subscribes. The professional services organisation said they will formally identify their interested parties and their reporting requirements, especially any legal requirements for reporting. 4.) Leadership and commitment This clause places a greater emphasis on role of top management Top management must demonstrate leadership and commitment with respect to the environmental management system Nine specific areas are listed including being accountable for the effectiveness of the environmental management system, ensuring the environmental policy and objectives are compatible with the strategic direction of the organisation and integrating the EMS with other business processes. Relevance to the organisation: 1 th out of 13 Change required by the organisation: 5 th out of 13 Amount of environmental benefit: 1 st out of 13 One participant said: It is to engage with top management from a range of disciplines, for example: finance, human resources, facilities, procurement, and design, sales and marketing. This will then help when considering the impact of products and services throughout their life cycle. We will need to embed environment into Business Strategy. In the future it may be crucial to Business Continuity. There were a number of comments along the lines that there was a need for top management to be more involved with the environmental management system than it is currently. One respondent said: The EMS has been ordered from top holding management level and is not actively supported by our management; therefore the EMS must get a much higher importance and place in daily business. When this is achieved a significant benefit is to be expected. Another said: If the intent of the required activity is understood by the executives and is filtered down to the plant management for actions, then there is hope of moderate change. The view of survey participants in this area is reinforced by examining organisations who are often cited as exemplars of environmental and sustainability practice such as Interface (the designer and maker of carpet tiles) and Unilever. The turnaround in environmental performance at Interface was Page 6 of 14

7 driven by the late founder and chairman, Ray Anderson, who wrote a book based on his experiences Business Lessons from a Radical Industrialist. Paul Polman, the Dutch CEO of Unilever, has gone on record arguing that being less bad is just not good enough anymore: If the consumer goods industry does not move to a more sustainable model, most of its profits will be wiped out in 30 to 50 years, and if you are in food even earlier. Whether or not the changes to ISO will lead to greater top management engagement in environmental management remains to be seen, and is discussed by Marek Bidwell in this related article: / 5.) Environmental Policy Additional commitments are required in the policy to protection of the environment specific to the context of organisation. These requirements are not prescribed, but examples include sustainable resource use, climate change mitigation & adaptation and protection of biodiversity & ecosystems. Relevance to the organisation: 7 th out of 13 Change required by the organisation: 11 th out of 13 Amount of environmental benefit: 10 th out of 13 Written responses to this change were brief along the following lines: Will just need to broaden existing policy ; This will hopefully make the policy more meaningful ; Climate change will need to be formally considered. ; and Often the scope is defined in the policy, so will need to reflect the requirements of the new standard, for example, the effect of external factors on the EMS. It appears that respondents are focussing on the act of updating the environmental policy document. Readers should note, however, that once a commitment is made in the policy it becomes auditable and evidence must be available that the organisation is meeting the commitment. 6.) Threats and opportunities When the survey was distributed it was based on the Draft International Standard that required the organisation to determine the risk associated with threats and opportunities. This requirement was later changed in the final version, requiring the organisation to determine risks and opportunities in relation to its environmental aspects, compliance obligations, and issues associated with the context of the organisation. Nevertheless, the feedback provided by the survey is still considered informative, if this change is born in mind. Page 7 of 14

8 Relevance to the organisation: 8 th out of 13 Change required by the organisation: 3 rd out of 13 Amount of environmental benefit: 8 th out of 13 The metal products manufacturer, who ranked this change as high for relevance and moderate for environmental benefit said: The methodology determined to be used for the best results in dealing with risk will be and will be one of the most difficult areas in the new standard. The concern globally for risk and threats is consistently rising and causing review of many factors internal and external to the facility. The aerospace organisation, who also ranked this change high for relevance, but low for environmental benefit said: We already identify environmental threats and opportunities that need to be addressed per our process for determining and managing significant environmental aspects. This change may lead to business benefits in addressing risk/threats/opportunities for the organisation, but will not lead to any significant environmental improvements. Environmental managers are considering whether or not their existing systems cover this requirement. The professional services organisation said: Need to expand existing aspects register, adopt a more quantitative risk based approach. May need input from other colleagues (sustainability team) to address correctly, whilst the passenger transport executive said: We already identify risks. Clearly, this is an area that will require chance for many organisations if they do no already consider environmental risks and opportunities, over and above environmental aspects, that was already a requirement of ISO 14001: ) Planning to achieve objectives The plan to achieve objectives (formally objectives & targets) must be more specific than previously, including: i) what will be done ii) resources required, iii) who will be responsible iv) when it will be completed v) how results will be evaluated. vi) how it will be integrated into the organisations business processes. Records need to be kept showing plans to achieve the environmental objectives. Page 8 of 14

9 Relevance to the organisation: 6 th out of 13 Change required by the organisation: 8 th out of 13 Amount of environmental benefit: 3 th out of 13 The results show that this change ranked higher for environmental benefit than the other two considerations. The sentiment of a number of the respondents was summed up by the aerospace organisation who said: We already do this, so for my organisation, the benefit may be more limited; however, for organisations that have not included this information in the past, there may be moderate benefit in the increased specificity and accountability in the planning process. On the other hand, one respondent who had previously expressed concern over a lack of top management involvement in the EMS said: As said before management is not keen on EMS and therefore this will need a change of attitude. Benefits will be small because objectives will be distilled from commercial objectives rather than the other way around. 8) Competence The text is almost the same under this clause as in the 2004 version, but with the addition of a requirement to evaluate effectiveness of actions taken to acquire competence and identify competency requirements of persons working for on behalf of the organisation that could affect its environmental performance. Relevance to the organisation: 12 th out of 13 Change required by the organisation: 12 th out of 13 Amount of environmental benefit: 12 th out of 13 It is perhaps not surprising that this change was ranked of less importance by the survey group because it is already a requirement of the quality management standard, ISO 9001, and eight out of the ten participants had ISO This was summed up by the professional service organisation who explained: This is already addressed in existing systems. Might need to pull the competency information to together or signpost from EMS, for example determining internal auditor competence. 9.) Communication This is a new requirement: to plan and implement a process for internal and external communications including: what, when, with whom, and how; taking into account compliance obligations. Information that is communicated must be reliable. Page 9 of 14

10 Relevance to the organisation: 10 th out of 13 Change required by the organisation: 10 out of 13 Amount of environmental benefit: 6 th out of 13 The variety of responses to this topic were varied, depending upon the sophistication of participants existing communications systems. For example, the passenger transport executive who ranked the change required as moderate said: We may need to formalise existing arrangements, while the a vehicle safety systems organisation, who range the change required as high said, Our communication procedure really needs an improvement to comply with this new requirement. The professional services organisation outlined the approach they would take to develop their communication process: We will probably need to conduct a mapping exercise to identify who we need to communicate with, what we need to communicate and a method for delivering the information. This includes taking into account compliance obligations for reporting, for example, Green House Gas reporting, ESOS and the Carbon Disclosure Project. Three of the ten survey participants were small or medium sized organisations (SME) employing between 100 and 249 staff. These organisations ranked the relevance of this change lower, on average, than the remaining seven organisations who all employed more than 250 staff. The three SME s all were manufacturing organisations and it is therefore likely that they perceived lower levels of stakeholder interest in their activities, compared to some of the other respondents such as the airport and offshore oil and gas organisation. 10. Value Chain - Procurement There is a new requirement, to consider a life-cycle perspective when identifying environmental aspects including upstream issues, and a specific requirement to determine environmental requirements for the procurement of products and services, as appropriate. This may mean, for some organisations, considering the environmental impact of the products purchased, in addition to the environmental performance of company that supplies them. Relevance to the organisation: 5 th out of 13 Change required by the organisation: 2 nd out of 13 Amount of environmental benefit: 9 th out of 13 Reponses to this topic were heavily related to the industry sector of the organisation and the complexity of their supply chain. The metal fabrication organisation, who ranked this change as moderately relevant said: This will be a change that if understood correctly should add new perspective in both the program development and documentation as well as regulatory concerns and Page 10 of 14

11 a higher review with new personnel i.e. purchasing or schedulers. There is acknowledgement here that certain personnel will have greater involvement with the environmental management system than before as the scope of the system is extended to cover the supply chain. For other organisations however, this new requirement was less, either because they offered consultancy services, rather than a product, or they already include environmental issues when purchasing. 11.) Value Chain Design and Downstream There is a new requirement for the organisation to establish controls to ensure that environmental requirements are addressed in the design and development process for the product or service, considering each stage of its life cycle. This may include design, development, delivery, use, and endof-life treatment of products and services. Relevance to the organisation: 3 rd out of 13 Change required by the organisation: 1 st out of 13 Amount of environmental benefit: 4 th out of 13 Respondents thought that these new requirement, for environmental design, would require the greatest amount of change for their organisations, with seven out of the ten categorising this a significant change. The metal fabricator, that also offers technical support services such as die designers and metallurgists gave a similar response to the question on procurement: This will be a change that if understood correctly should add new perspective in both the program development and documentation as well as regulatory concerns and a higher review with new personnel i.e. purchasing, product managers, schedulers and sales, if not engineers. Organisations who have little control over the design process, or who make standard commodity products, may struggle to apply this requirement. For example, one organisation said: Our main customers are big and then we can hardly influence them. Having a relatively small market share our impact is minimal and the competition high. The professional services organisation said: It is difficult to apply this requirement to our business as we provide services / consultancy rather than a product. Will need some thought as how best to address to add value. This may be through environmental / sustainability design guidance, offering client options to clients Page 11 of 14

12 12.) Performance Evaluation This clause requires the organisation to effectively determine its monitoring and measurement activities: What to monitor and measure The methods to use The environmental performance criteria (KPIs) When it shall take place How and when the results shall be analysed and evaluated Although monitoring and measurement was a requirement of the 2004 version of the standard, the 2015 version is more prescriptive about defining the methods to use, establishing performance criteria, and analysis of results. Relevance to the organisation: 4 th out of 13 Change required by the organisation: 9 th out of 13 Amount of environmental benefit: 11 th out of 13 For some of the respondents, this does not represent a change, so much as a strengthening of the existing evaluation process. The passenger transport executive said: We will have to do what we already do, but more detail and the professional services organisation said: This is already being conducted, but we may need to pull information together into one place, or signpost from EMS. We will have to ensure of methods are consistent, reliable and possibly externally verified. However, the developer and manufacturer of silicone liners said: Evaluation is the hard part of any management system and will require the largest change in our daily business. Eventually it will have significant benefits but we are far from that point now. 13.) Compliance Status The requirements in this clause are more explicit than before, and they are broken down into three sections: i) determine the frequency that compliance will be evaluated ii) evaluate compliance and take action if needed, and iii) maintain knowledge and understanding of compliance status. Requirement i) is more specific, and iii) is new. Page 12 of 14

13 Relevance to the organisation: 2 nd out of 13 Change required by the organisation: 7 th out of 13 Amount of environmental benefit: 7 th out of 13 This was ranked at the second most relevant change by the respondents, with seven of the ten categorising it as highly relevant. Nine out of the ten participants also reported that they have one or more environmental permit, and it is likely that their regulated status increased the relevance of this change. As regulated businesses however, some already monitor their compliance status, for example the aerospace organisation said: We are already doing this, and the passenger transport executive said: We'll have to formalise what we already do. Other respondents believed that they had more work to do in this area. The manufacturer of vehicle safety systems said: The new part of this requirement is not included in our existing procedure and the manufacturer of silicon release liners said: This was one of the findings during the initial audit. We do have a great system now but we are finding out that it is very hard to make sure the requirements list is complete. Summary Taking an average across the ten survey participants, the following topics were ranked as the most for the each of the three criteria: Relevance to the organisation: 1. Leadership and Commitment 2. Compliance Status 3. Value Chain Design and Downstream Change required by the organisation: 1. Value Chain Design and Downstream 2. Value chain procurement 3. Threats and Opportunities Environmental benefit: 1. Leadership and Commitment 2. Understanding the organisation and its context 3. Planning to achieve objectives However, there was some variation of rankings between participants for certain topics. Larger organisations ranked topic nine communication higher than smaller organisations; organisations who had more complex supply chains ranked topics ten and eleven for procurement and design as more than those in the service sector; and organisations with more mature (and possibly more strategic) systems ranked the change required as lower for topic two understanding the context of the organisation. Page 13 of 14

14 It will be interesting to follow up this survey, after the transition period, to see if these opinions have changed. About the authors Marek Bidwell is Director of Bidwell Management Systems, a Chartered Environmentalist Assessor and visiting lecturer in environmental management at Newcastle University, Marek has led the design, development and implementation of environmental management systems at a wealth of businesses across the UK. He is the author of a series of articles in The Environmentalist on the challenges of adaptation of management systems to the new standard, author of "Making the transition to ISO 14001:2015" and facilitator for the practitioner-led ISO 14001:2015 Road Test Group. Kirsten McLaughlin has over 15 years experience in the environmental management field, her main areas of interest are Environmental Management Systems, ISO 14001, environmental performance improvements and Environmental Auditing. In ever advancing areas of environmental management she has successfully applied her management skills to deliver projects for public and private organisations in a variety of sectors including aviation, manufacturing, pharmaceuticals, transportation and construction. She has experience of working in the UK, Europe and the Middle East. Kirsten is currently employed as Company Environment Manager for WSP Parsons Brinckerhoff in the UK. Dr Phil Longhurst is a Reader in Environmental Technology and Head of Centre for Bioenergy and Resource Management. His research interests include: the recovery and diversion of materials from landfill; energy recover from phytoremediation crops; risk assessment and studies on better regulation. He leads study modules in the Energy, Environment, leadership and management postgraduate programmes at Cranfield University. Contributors The authors would like thank all those who took part in the survey including the following: Kirsten McLaughlin of WSP/Parson Brinckerhoff, Daan Eerland of Loparex, Holly Reidenbach of BP, Andrea Szekely of Takata, Harriet Smith of Merseytravel and Andy Barton of Exeter International Airport. Page 14 of 14