Copyright 1994 Quality Digest. For subscription information contact Quality Digest at 800-527-8875. This material is provided as a service to the readers of this online service. This material may not be copied or transmitted in any form without the express permission of the publisher. First There Was ISO 9000, Now There s . . . ISO 14000 by Marion Harmon Not too long ago, ISO 9000 was like a bit player in a B-grade movie: a virtual unknown. Then, due largely to becoming an understudy of the European Community, the international quality management system began to get rave reviews and a large following. Now, 40,000 certificates and 95 countries later, ISO 9000 has become a world-class star in its own right. While ISO 9000 is now feeling the growing pains of its fame and the heat of new critics, it remains a bright star in the global business community. Now, a new standard looms on the horizon: ISO 14000. Still in its early beginnings, this newcomer to the international scene could become as famousÑor infamousÑas its older sibling. What is it? The International Organization for Standardization in Geneva probably didn't know it had a big hit in the making when, a decade ago, it charged Technical Committee 176 with developing quality management standards for organizations. The ISO 9000 series was its first big leap into the "soft" science of organizational management, and it was a doozy. Businesspeople the world over have heard of, if not felt, the impetus of ISO 9000. Now, ISO heads into another area of management--the highly complex field of environmental protection activities within organizations. For several years now, the environmental field has seen an escalation of national and regional standards. The British Standards Institution has BS 7750 on environmental management; the Canadian Standards Association has environmental management, auditing, eco-labeling and other standards; the European Union has eco-label and eco-management and audit regulations; and some two dozen countries such as the United States, Canada, Germany and Japan have introduced eco-labeling programs. After the rapid acceptance of ISO 9000 and the great increase of environmental standards around the world, ISO began an inquiry to assess the need for international environmental management standards. In August 1991, they formed the Strategic Advisory Group on the Environment, which was asked to consider whether such standards could serve to: * Promote a common approach to environmental management similar to quality management; * Enhance organizations' ability to attain and measure improvements in environmental performance; and * Facilitate trade and remove trade barriers. In the fall of 1992, SAGE made its go-forward recommendation to ISO's Technical Board, which then charged a new committee, TC 207, with developing international environmental management standards. Subcommittee members are official representatives from about 40 countries, including people from industry, standards organizations, government and environmental organizations. The standards, currently known as ISO 14000, will cover six areas: environmental management systems, environmental auditing, environmental performance evaluation, environmental labeling, life-cycle assessment and environmental aspects in product standards (see Figure 1). How does it affect you? The most obvious benefit of a single international standard is the worldwide focus it brings to the environment. After all, the end-product of any such system should be a cleaner, safer, healthier world for us all. The more organizations that focus on the environment, the better it should be for the world. But what does it mean for the individual business? Aside from the noble, lofty goals of global environmental excellence and harmonization, organizations may realize some more down-to-earth benefits from paying attention to these standards now. Corporations can show good faith ahead of time by getting involved now--showing an eagerness to comply can hardly hurt. Cutting down on bureaucracy is an appealing side effect, if it can be achieved. And the possible public relations benefits of showing that they're environmentally responsible corporate citizens can hardly be ignored. "U.S. companies need to make sure they are involved in this process because these standards will have a significant impact on how they manage environmental issues and standards," says Joel B. Charm, director of occupational health and product safety for Allied Signal Corp. in Morristown, New Jersey, and chairman of the U.S. Technical Advisory Group (TAG) for Subcommittee 1. Above all, the fact that companies may someday need environmental management certification to compete in the global marketplace could quickly overshadow all practical reasons and marketing ploys. Recent ISO 9000 convertees can attest to the strength of that argument. "Although voluntary, the ISO 9000 quality standard is something that's becoming necessary to do business around the world," said Dorothy Bowers, vice president of environmental and safety policy at Merck & Co., to attendees of the Global Environmental Management Initiative conference in March. "Similarly, the ISO 14000 environmental management standard may become a de facto requirement for being able to do business in Europe and other regions." Who cares? While many countries already have or are developing environmental management standards, a global standard will put a worldwide focus on environmental management and hopefully lead to harmonization of such things as rules and labels. The standard is meant to demonstrate commitment and provide a framework to move beyond compliance. Harmonizing international environmental standards will help, not hurt, U.S. industry, according to the American National Standards Institute. This sentiment appears to be the consensus view of many other nations as well. And the United States is right in the thick of the developments with ISO 14000. ANSI represents the United States at TC 207. ANSI, in turn, established a technical advisory group of about 200 environmental managers, government, association and environmental-group executives and other interested stakeholders. This group develops the positions ANSI takes to TC 207. "The lesson we learned from ISO 9000 was that the United States made a big mistake in not getting involved early in the ISO 9000 process," says Joe Cascio, program director of EH&S standardization at IBM in Somers, New York, and chairman of the U.S. TAG to TC 207. "We thought that ISO 9000 was not going to be applicable to the United States, that we had the Baldrige Award and all the other stuff. We've learned that we can't let things just develop and go on, and that's why U.S. industry is very active now on ISO 14000." To whom does the standard apply? According to the environmental management system working draft, the international standard has been written to apply to all types and sizes of organizations and to accommodate diverse geographical, cultural and social conditions. Beyond committing to continual improvement and compliance with applicable legislation and regulations, the standard does not establish absolute requirements for environmental performance. So two organizations engaging in similar activities but having different environmental performance may both comply with its requirements. A major issue that is yet to be resolved is to what exactly the standard applies. So far, it applies to plant operations, but there is a dispute as to whether it applies to products and activities as well. "The general view is that it applies to all three: products, activities and plant operations," reports Charm. "Some members, particularly Pacific Rim countries, say that products should not be included because they are afraid it will create a nontariff trade barrier. But the prevailing view is that they should be. I think we've been able to accommodate that concern with the inclusion of products in a more general way." Disclosure--externally communicating the organization's environmental program--has already been built into the standard. In fact, it was the U.S. recommendation that disclosure be included into the standard itself, notes Charm. And they have resolved that third-party auditing and self-declaration are both acceptable. "A company must set up a process for externally communicating on its environmental program," says Charm. "We don't say how and what must be communicated, just that a company must set up a process." European countries, particularly the United Kingdom and Germany, would like to go into extreme detail in this area, observes Charm. But because such detail could lead the standard to becoming incorporated into the U.S. legal structure, the United States stands firm in its opposition. "We think the international standard is a very big step forward, and having companies sign up to these standards should be encouraged," emphasizes Charm. "But if it winds up being a penalty-type situation, then it might be an impediment to moving the standard forward." But being too generic will serve no purpose either. Charm concurs: "There is a legitimacy to having the standard be considered by the Environmental Protection Agency to be a good environmental standard of management leadership. So we don't want to take it out of the EPA realm, rather, leave enough flexibility in interpretation." How will the ISOs relate? The first goal is to have ISO 14000 be the pre-eminent environmental management standard, says Cascio. The next goal, which is further down the line, is to join ISO 9000 and ISO 14000 together. Virtually everyone involved in developing the environmental management standards agrees that they should conform to the philosophy and architecture of the ISO 9000 quality standards. "Our belief is that ultimately these two will be joined," explains Cascio. "The environmental management standards will be incorporated, probably by reference, into the ISO 9000 standard. Our view is that, when you get audited, there really should only be one audit, not multiple audits." To facilitate this eventual convergence, a joint task force between TC 176 and TC 207 meets regularly to ensure that the two committees share the same vision. Joining the two standards could help cut costs and prove less disruptive for auditees. But does this mean that ISO 14000 may become a requirement to do business in certain countries, especially European ones? Cascio says there is a significant likelihood that, soon after the standards are published, facilities will need to be certified to them in order to sell their products--particularly in Europe. So organizations would seem well-advised to find out exactly how the environmental management standards will affect them in the long run. Getting in on the ground floor could help managers get a jump on lining up their environmental management systems with the international standards. This may even save them from some expensive consulting fees for learning even the most basic facts about the standards. It's no big secret that ISO 9000 has been under fire of late for rampant commercialization and possible misuses and abuses by consultants. At the very least, assuming no fundamental impediments, establishing systems to cover environmental management, auditing, performance and maybe even life-cycle analysis will be costly, warns Cascio. Third-party certification would also add to that cost. He also cautions that such systems will require integration into many levels and processes of a facility, touching on the fundamental parameters of management and decision making. Managers may find that providing training and gaining buy-in will begin to eat into their budgets. Small companies may find this especially prohibitive. While Cascio warns of the costs of establishing environmental systems, Charm is more optimistic about the way things will turn out. "That's why we're trying to avoid some of the excruciating detail," says Charm. "If we can do this, then we think it applies to small companies as well as large, and there will be no financial barrier to a small company implementing this kind of standard." What's happened lately? The working groups have met several times. At a plenary meeting in May in Brisbane, Australia, Subcommittee 1, which has about 50 members, further refined the environmental management system standard, which is still a working draft. The environmental management system will be the main standard that organizations will be certified to. "We have the body of the standard largely completed," reports Charm. "We also have a good start on the annex to the document, which will give further amplification of what's in the main part of the standards." The annex-drafting group will further define how much detail will actually go into the standard--how much generic language vs. specific language. At the May meeting, Subcommittee 1 agreed that the annex group will meet in Chicago at the end of July and that the full subcommittee will meet again in Vienna in September, at which time they are scheduled to convert the standard to a committee draft. Then the draft will begin circulation for approval by other countries. Those comments will be due back to the committee by the end of December, resolved during January and then the revised committee draft will be issued in February for official ballot. Charm says the target date for publication is Jan. 1, 1996. "It's a very tight deadline," admits Charm. "It's probably cutting in half the normal time for the development of a typical ISO standard." Why the rush? Charm gives a couple of reasons. First, there's a great deal of pressure to have an international environmental management standard established for people to be able to use. Second, there's specific pressure within the European Union to have ISO 14000 emerge so that it can be the backup document for the Eco-Management and Audit Scheme (Emas) in Europe. The European Committee for Standardization (CEN) has agreed that if ISO 14000 emerges in a timely fashion, then CEN will refer to ISO 14000 as their supplementary document. CEN, a regional standards-making organization in Brussels, has been charged by the European Union with harmonizing the differing national standards of the EU countries. If ISO 14000 is not completed in that time frame, however, the European Union has the option of developing their own backup document. "It's not a competition at the moment, but that depends upon whether we can finish the standard, ballot it and complete it, and then publish it within a two-year period," notes Charm. How much is too much? While other areas of the international standard have been meeting with controversy, the one that's turning out be more difficult than originally anticipated is the environmental management system, reports Cascio. The main point under contention is the regulatory elements that should enter (or not enter) the management standard. To try to make a long story short, the United States relies heavily on a command-and-control system in the environmental arena; Congress passes laws, the EPA passes regulations and strictly enforces them with heavy fines and penalties. The Europeans tried to set up a command-and-control system as well, but it never really worked out, says Cascio. "Europe wasn't able to set up the same level of supervision and stringency in their enforcement tactics, so their system has not been nearly as effective and coercive as the American system in getting industry to toe the line in environmental protection," says Cascio. The European countries individually have their own versions of the EPA, some closer to the U.S. system than others, but they need something different to pass regulations collectively at the European Union level. One such system is the Emas regulation, due to come into force in spring 1995. Under the voluntary Emas regulation, the European Commission can "recognize" national, European or international environmental management standards and audits as equivalent to those of Emas. Companies certified as meeting these would be considered to comply with the requirements of the EU regulation. Under Emas, companies will be audited by private-sector third parties, explains Cascio. Basically, the scheme provides for a system of disclosure that enlists the assistance of the public either through discrimination of the marketplace or through information that the public acquires. The companies themselves are required to produce a public statement on their environmental system. "In a sense, Emas is the Europeans' answer to their lack of enforcement," says Cascio. "Through a process of third-party audits and disclosure of information, they will enlist the help of the public to do what their enforcement agencies have not been able to do, which is to force companies to toe the line on environmental protection." Cascio says that while the European environmental regulations system is superior to the U.S. system because it allows for verification of company statements and for less-coercive third-party audits, the United States has no need for another system containing regulatory provisions. "We already have a command-and-control scheme in the United States, so we're not at all willing to accept any performance criteria in the management standard," declares Cascio. "We're not going to accept any requirements for performance because we already have the EPA to contend with, and we don't want ISO to contend with as well." An example of this is the issue of environmental aspects of products, says Charm. He explains that Emas and BS 7750, the environmental management standard published by the British Standards Institution, contain a complete list of all the environmental issues that have to be explored, including controlled and uncontrolled emissions to the atmosphere, controlled and uncontrolled discharges to water or sewers, solid and other wastes, contamination of land, use of land, water, fuels and energy and other natural resources, discharge of thermal energy, noise, odor, dust, vibration and visual impact. "The U.S. position is that no list will ever be complete," says Charm. "Some of these items might be appropriate, but many are not. You have to write it in such a way that it lets the company define the important issues for its products, activities and plant operations." Rozell Hunter, an attorney at the Brussels office of Hunton & Williams, expresses a similar sentiment in the March 16, 1994, issue of "World Environment Report." Environmental standards making in the European Union could pose distinct barriers to trade and even barriers to further environmental rule making, warns Hunter. Goals outlined by the European Parliament and European Commission have created a rigidity that makes negotiating with bodies like ISO difficult, he says. And differences between the discovery and enforcement traditions of the United States and the European Union "could pose problems" for U.S. business. The specific elements of ISO 14000 that the Europeans currently want in and the United States (and other countries) want out include continuous improvement of performance and a required evaluation of suppliers. The impasse may cause the Europeans to create their own standard. Where will this lead? "A lot of momentum is building up behind ISO 14000 because of the success of the ISO 9000 standard," says Cascio. "That success is going to spill over onto ISO 14000, so if the Europeans develop their own standard, the ISO standard will overshadow it anyway." What else is happening? The other areas of ISO 14000 are in various stages of development. Cascio reports that environmental performance evaluation, an area they're having to basically invent from scratch because it is less well-developed than others like environmental management systems and environmental auditing, is moving along surprisingly well. "There is a lot of consensus amongst all the participants," says Cascio. "We were originally worried about the differences of views on that subject between the United States and some European countries, but it turns out that those differences have been reconciled. This is very satisfactory, given that this was probably the most divisive and controversial of subcommittees." Because environmental performance evaluation didn't have the pre-existing bodies of knowledge and documents and such that other areas had, they haven't begun to write a document yet. The documents for techniques and methodology in performance evaluation will not be available until later next year, says Cascio. The environmental auditing group is working on three main documents: a specification document for auditing environmental management systems, a guidance document on general principles of environmental auditing and a document on auditor qualifications. These three documents have been elevated to committee draft status. This does not mean that they're finished; they still must be circulated for additional comments and, after those comments are reconciled, maybe early next year, they will be circulated for balloting, explains Cascio. "The environmental auditing documents are moving along in a relatively satisfactory way," says Cascio. "Even though some controversial issues still need to be resolved, there is recognition at the international level that the documents have made a lot of progress." Because environmental management system audits are not compliance or performance audits, the environmental qualifications of the auditors need not be as stringent, says Cascio. "You are essentially auditing a management system, and a good auditor with good skills and experience should be able to do this," imparts Cascio. "My general feeling is that those people need not be environmental experts nor have even moderate environmental credentials. Light environmental credentials but heavy experience in auditing concepts and techniques will stand them in better stead." Where's the science? The product evaluation section of ISO 14000 is going a little slower, notes Cascio. In the organization evaluation section, political issues come into play, but in product evaluation, scientific understanding and consensus are the issues, and they can't be rushed. Committee members must devise uniform approaches to the conduct of life-cycle assessments and product criteria, which are then used to award labels and such to discriminate in the marketplace. Environmental labeling programs have sprung up all over the map: the Blue Angel, the Green Seal, all the various programs in all the various countries. The practitioners of those programs have a vested interest in keeping whatever techniques they develop in the status quo, observes Cascio. "Rather than it be a scientific exercise, which it should be, it turns into a political exercise, which it shouldn't be," says Cascio. "The challenge there is to put those disciplines of environmental labeling and life-cycle assessment on some kind of a technical footing." A major problem is that a lot of the science is not yet available in this area. Add this lack of technical knowledge to political scrambling, and consensus-building could take some doing. "Right now people are positioning themselves," says Cascio. "They're figuring out where everyone else is and trying to position themselves to use the process at this point." What will happen to other standards? Understanding ISO 9000 and becoming familiar with national standards like BS 7750 and Emas and voluntary initiatives like the U.S. chemical industry's Responsible Care program, all recommendations that Cascio has put forth, will only help the global situation. National and regional standards present no small task to put together, and they exist for a definite purpose. BS 7750 is the compilation of the latest thinking of 450 participating organizations of all types--businesses, consumer organizations, users. Its third revision was published January 28th, and BSI says that use of the standard may be seen as a first step to meeting European eco-auditing requirements. Once the international standards become firmly established, how will all the existing and still-emerging standards and regulations fit together? "That's the big challenge for all the coordinating bodies, to make sure that there are no gaps and no duplication," says Bill Cormie, in charge of sales development for BSI in Vienna, Virginia. "We've seen the experience with ISO 9000, how difficult it is to coordinate a worldwide input. Some people are ahead of the posse, and others are still in catch-up." Another question is how involved a company, especially a U.S. firm, should get in all the different standards and regulations. "That depends on the level of involvement," counsels Cormie. "At this stage, companies should certainly have awareness, especially if you're an exporter to Europe. Many of the businesses in the United States are world-class with a global reach, so they need to take into account the Eco-Management and Audit Scheme, and the Eco-labeling that goes with it. "From the BS 7750 point of view, there are two ways of looking at these regulations: Do I have to because I'm being pressured into it, or is it a noble thing to do? From the second point of view, I think every American business should be looking at this model and saying: We're doing this anyway, or, here are some gaps that we need to plug.'" What's next? Much as we've stepped into a new era of international thought with quality management, so we seem to be headed with environmental management. Whether these international standards will develop in an orderly and timely fashion remains to be seen. Already hampered by conflicting economic interests, geopolitical differences and talk of trade barriers, ISO 14000 may have a tough road ahead. But its supporters may have learned some lessons from big brother ISO 9000--they are already anticipating many issues that have plagued the quality system standards, such as abuses by third-party registrars and consultants, and are addressing these issues ahead of time. The world will wait while the understudy learns it lines and heads for the big screen. We will watch to see if this standard becomes a big star. For more information about ISO 14000, contact the American National Standards Institute at (212) 642-4900. QD