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SPRING 2002

SAY WHAT YOU DO, DO WHAT YOU SAY

(The first in a series of articles on environmental management systems)

It is an old saw among those tasked with the care and feeding of quality systems that, stripped of

jargon and boiled down to a bitter essence, formal structures such as the International Standards

Organization (ISO) Quality Management System (or the ISO 9000 series) only stipulate that an

organization say what it intends to do and then actually do it in the hope that the result will be a

measurable improvement in quality. This principle also applies to environmental management

systems (EMSs). Say what you do, do what you say.

Ah, but what to say? There is a diversity of thought about what exactly an organization should

say and what exactly constitutes an EMS. This diversity is no surprise, considering the varying

needs and issues confronting organizations. Amidst the chaos, however, order arises. Several

models of environmental management have been developed that either define a structure or

delineate the principles on which a system must be based. The most well-known is the ISO

Environmental Management System Standard 14000 series. There are also a number of

industry-specific models, such as the Chemical Manufacturer's Association's Responsible Care

program.

These models are based upon common themes that are exemplified in the North American

Commission for Environmental Cooperation (CEC) guidance document “Improving

Environmental Performance and Compliance,” which was developed by the United States,

Canada, and Mexico. The document identifies 10 basic elements of an effective EMS, which

include:

• an environmental policy that clearly communicates the organization's commitment to compliance, prevention, and continuous improvement;

• delineation of regulatory and management requirements to which the organization is

subject;

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• performance objectives specific to the elements of the general policy;

• definition of the organization and identification of specific responsibilities to ensure that

targets and objectives are met and that adequate resources are provided;

• identifying, planning, and managing operations that affect achievement of the EMS objectives;

• maintaining documented procedures for preventing, detecting, investigating, reporting,

and correcting conditions that may affect meeting EMS objectives;

• implementing training of personnel with responsibilities that affect the ability to meet EMS objectives;

• integrating the EMS into the organization's general management processes, including

decisions on capital improvement, product and process design, training, and maintenance;

• maintaining records relevant to the EMS in an orderly structure; and

• periodic documented, objective reviews of the organization's performance in achieving its EMS objectives, including an assessment of how well it supports efficient management of the organization.

An EMS with these elements can be relatively simple or, depending on the nature of the

organization's needs, quite complex. In any case, the basics must be there: identify where the

organization is going (call it, say, a policy), define how it will get there, go there, and document

what happened along the way, i.e., "plan, do, act, and check."

Having touched upon the what, perhaps we should ask why? Philosophically, it can be argued

that all organizations have an environmental stewardship responsibility to their communities

(see, e.g., the International Chamber of Commerce Charter on Sustainable Development).

Market forces provide additional motivation. For example, Ford, General Motors, and

Daimler/Chrysler have informed their supply networks that an EMS is a basic requirement for

doing business and have stipulated that the EMSs of their suppliers must conform to the ISO

14001 standard. There are rumors that other bell-weather industrial sectors will follow suit,

including consumer electronics and aerospace. Certain geographic markets also effectively

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mandate an EMS as a prerequisite for entry, particularly the European Union and, to a lesser

degree, the Japanese and Southeast Asian markets.

For those who will not answer to the market rudder, there is the regulatory rock. USEPA's

National Enforcement Investigations Center has identified inadequate EMSs as a root cause in

many enforcement actions. Consequently, the USEPA typically incorporates development of an

EMS into its compliance enforcement settlements and has issued guidance to this effect.

Need it be market pressure or enforcement that drives an organization towards formalizing an

EMS? Clearly not, considering the significant library of case-studies in which companies have

realized large cost-savings and major process improvements through an EMS. While there is no

magic, measurable improvement in environmental performance and competitive advantages can

accrue from saying what you do and doing what you say.

Please look for a discussion of the ISO 14001 Environmental Management System Standard in

our next newsletter.