ISO 14001: Comply with Laws, Prevent Pollution, Continually Improve
“When something goes wrong, a company has an accident or a mistake, we immediately blame that company for not doing things right. And then, inside that company, it goes down from the plant manager, whose neck is on the line, and he starts looking for somebody he can blame,” says Molly Long. “There’s a hierarchy of blaming that occurs. It’s the picture of the two-story outhouse. No one wants to be on the bottom floor.”
As president of A.W.E. Consulting, Long audits compliance with ISO 14001, which, she describes as, “an international standard that helps people coalesce their environmental management into something that’s meaningful and trackable.” When a business seeks ISO 14001 certification, it enters into a process that changes that blaming mentality by putting responsibility where it belongs: at the top.
In Part 1, we interviewed Long about the abundance of laws, rules, and regulations surrounding environmental management. In Part 2, we talk with her about about her role as an ISO 14001 auditor. In Part 3, we’ll find out about Long’s role as an environmental consultant. — Publisher
BPGL: What is ISO 14001, and why should businesses care?
LONG: ISO 14001 guarantees the community in which the business operates that they are doing what they can to meet their environmental commitments: pollution prevention, compliance, and continual improvement. It sets up a framework for businesses to interact with their community, to comply with laws, and to make sure that the business is sustainable.
The primary purpose is to protect the environment, but businesses also can use ISO 14001 to help them innovate. The Environmental Protection Agency (EPA) sets standards so that everybody can be safe and healthy, and no one blows things up and kills fish and so on. But, if a business wants to, they can take it further and do what is environmentally correct and, at the same time, innovate a benchmark for other businesses to follow.
The ISO standards are created by the International Organization for Standardization. It’s a much broader group of people than if you just had legislators who were affected by their local issues. And there are lots of people who submit comments on the standards, too.
BPGL: As an ISO 14001 auditor, what are you looking for in terms of environmental management?
LONG: A lot of companies already do environmental management. They have to, because of all the regulations, but they don’t have a systematic way of doing it, and they’re not very good at collecting data about performance.
The way most companies interact with the environment is, “The EPA tells us we have to do something, so we’re going to do it this way.” They’re not necessarily doing it the best way, the way that’s the most efficient for them. They’re just doing it because they have to do it.
But the best environmental management involves three basic things:
- Defining what needs to get done
- Defining who needs to do it
- Identifying the things that will tell you whether it’s been done properly
A lot of people do the first part, or maybe the second part, but when it comes to measuring whether it was done properly or effectively or in the best way, they don’t do a lot of that. So ISO 14001 sets up a system that is driven by the top management in an organization. Top management uses this data on performance to help them meet three basic commitments:
- To comply with laws and regulations that apply to them.
- To prevent pollution wherever possible. So even if a law or regulation doesn’t tell their business they have to do something, but they know that it will prevent pollution, they pledge to do it.
- To continually improve. They try to make their business better, more efficient, and more effective at preserving the environment, at the same time making it more economically feasible and more sustainable.
Everything each employee does must be in line with those three commitments, which are stated in the organization’s environmental policy. The standard recognizes that the ultimate responsibility lies with top management to meet these commitments and provide the necessary resources to get the job done — it breaks the blaming cycle.
BPGL: How does a company get certified as ISO 14001 compliant?
LONG: The pathway to certification is through an independent body. If somebody wants to register their system to the ISO 14001 standard, they have to go to an authorized registrar. The business’s relationship with the registrar is as auditor and auditee. We differentiate between compliance and conforming, because compliance refers to laws and regulations, but the ISO standard is voluntary. Also, unlike most legal requirements, the requirements of the standard can be implemented in a variety of ways and still be considered conforming.
An audit is similar to an EPA inspection, except that instead of assessing compliance to a few environmental laws and regulations, the auditor is looking at the organization’s approach to environmental management holistically, all the ways their operation can affect the environment, both positively and negatively. The auditor for the registrar visits the facility to determine if they’re meeting the requirements for 14001, or whatever standard it is that they want to become registered for, so they can recommend that the organization receive certification for their efforts.
But certification is just the start. In a systems audit, we’re looking at the management of all media — air, water, and land, as well as effects to the community and natural resources use. We also look to see what positive impacts an organization is having on the environment. When a business has met the baseline for compliance, we want to take it a step further and help them make improvements to their management of environmental issues. We have to see evidence of that improvement in order for them to keep certification.
BPGL: Is ISO 14001 certification voluntary or a requirement for all businesses?
LONG: It depends. ISO 14001 is a requirement for companies that want to do business or sell things overseas. But for companies that just do business in the US, it’s not a requirement, yet. Many automotive companies require their suppliers at various levels to be certified, as they are themselves.
In some states there’s an environmental award issued by the governor or by a state agency, or even by the EPA, which has an environmental performance track. The award is a special type of recognition that has benefits that go along with it. And, often, one of requirements for getting into those programs or awards is that a business is a 14001-certified system. That’s as far as we’ve taken it in this country.
I think we place too high a value on compliance with laws and regulations. Our focus on compliance skews the metrics for performance by equating compliance with doing what is best for the environment. ISO 14001 requires the focus to shift to efficiency and sustainability, but many do not understand this. Also because it is voluntary, ISO is seen as less stringent, so businesses, regulators and the community at large still view compliance as the gold standard for environmental stewardship. We’re really missing the boat here.
Think of driving your car within the posted speed limit — you are complying with a law, but it doesn’t mean you are a good driver, or that you are committed to improving your driving skills. Lets face it: Many drivers focus on avoiding getting caught speeding more than they do driving as well as possible. It’s no different with environmental regulations.
Sure, obeying the laws is important, but our laws aren’t always the best option for environmental protection. Plus, laws don’t require you to improve or be more efficient — the EPA doesn’t care if businesses operate efficiently, their primary concern is for the public welfare. But as we talked about before, using laws to eliminate businesses because of environmental concerns is no more sustainable than allowing businesses to pollute as much as they want.
BPGL: Are many US businesses opting for ISO 14001 certification?
LONG: The US lags far behind the rest of the world in putting ISO 14001 systems in place. Any kind or size of operation you can think of can implement the standard, whether it’s a mom-and-pop grocery store or a not-for-profit organization, an office building, or a major industrial facility. And it’s an international standard, so it doesn’t just mean that the US can do it.
BPGL: Is a lack of efficiency something the environmental manager should be watching for?
LONG: Of course. Businesses want to be as profitable as possible, but you can’t maximize profits when you operate inefficiently. In ISO 14001, we have to look beyond compliance and understand the metrics that indicate good environmental performance as well as the context of the business, in order to make a judgment about whether they’re actually being successful at protecting the environment, being efficient, and becoming a sustainable business.
BPGL: So in some cases you’re an auditor and in other cases, you’re a consultant?
LONG: Exactly. I play two very different roles in my career. And the two really don’t meet. They can’t meet. I could never audit somebody that I consulted and I would not consult somebody that I had audited.
Consultants and auditors aren’t miracle workers — successful environmental management is up to top management. They have to be committed and supportive of environmental management, or it doesn’t work. Something I see everywhere is that companies hire an environmental manager, and he becomes the scapegoat. He’s the person that gets blamed whenever something goes wrong. But that’s just one person overseeing the activities of many other people, sometimes hundreds or even thousands, who all have the ability to impact the environment in some way through their work. I can speak to this, because I was in this position. One environmental manager, or even a small group of them, cannot possibly know what any one person is going to do right or wrong on any one day, and cannot possibly carry out all those activities by themselves just to ensure they happen properly.
Regardless of this impossible scenario, it is the reality in most traditional compliance-based system: all the onus comes back down on one person’s shoulders, the environmental guy/gal. So when mistakes are made, there’s a blaming culture that is very much out there, and it happens at all levels. But blaming doesn’t solve any problems.
BPGL: But how do you get away from that, when it all rolls downhill?
LONG: ISO 14001 tries to change that. The first thing it asks is, “Who is ultimately responsible?” Top management. They’re the ones who need to provide the resources to be able to get these things done. And that means resources throughout the organization. So you can’t just hand it to one person and say, “Here you go, here’s your system.” I try to work with management so they can get the right information to the right people, so they can each do their own work properly. That is so key.
BPGL: How can anyone be expected to be compliant when they can’t possibly know all the laws?
LONG: Being an environmental manager in a traditional compliance-based system is almost an impossible job. There’s no one person who can know everything, every law that is out there. I don’t profess to know even close to a small decimal point of all the laws that are out there.
This is one of the things I really like about 14001. Of course, you have to know what laws apply to you. However, at the end of the day, if you’re in doubt, you have your two other commitments to fall back on: Is what you’re doing preventing pollution? And is what you’re doing helping you to get better? If you meet those other two commitments, you are usually in compliance as well. By the same token, if those two questions aren’t answered, it doesn’t matter whether you’re compliant or not.
Compliance is ultimately arbitrary, because the same laws often apply in different environments, and also because they are influenced by politics and culture. For example, who is protecting the environment better? California doesn’t allow you to dump oil on the ground, but they do exempt some other nasty stuff from environmental regulation because of political lobbying. Whereas Mexico doesn’t care too much about oil on the ground, but you have to plant a lot of trees to offset the land you took up to build a parking lot.
ISO 14001 provides the tools for moving beyond compliance to arbitrary laws and begin following the path to true sustainability. It helps its adherents make sure the right people are doing the right job, and that they have adequate resources. It eliminates the blaming cycle by assigning accountability and responsibility to those with the proper authority. It also demands cooperative effort to find solutions that address the roots of problems rather than their symptoms, and recognizes that you can’t push your problems off on someone else. These are the management concepts I try to help people grasp, not only as an auditor, but as a consultant and trainer.
BPGL: Are you seeing a decrease in voluntary compliance in this economic downturn?
LONG: It’s interesting, because a lot of people are asking, “Is this economic slowdown affecting people’s ability to comply with environmental laws, are they cutting corners, things like that?” Actually, what I’ve found in my travels, has been more that people are taking the time to focus on some things that they don’t have the time to do when they’re running full bore. They’re doing maintenance, they’re taking the time to do some projects. So actually, we’re seeing some environmental improvements.
At least at this stage, we’re seeing that people are taking some time to do the little things that don’t cost a lot of money but the kind of things they couldn’t really justify in the course of day-to-day operations. For example, they’re organizing so that parts and materials are inside or in areas where they are less likely to impact the environment. They’re getting the stuff out of the way so they can continue running their lines. Now they’re saying, The line’s down, let’s organize this area. Let’s make it neat and safe and as environmentally friendly a space as possible.
Part 2: ISO 14001: Comply with Laws, Prevent Pollution, Continually Improve (Top of Page)
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