Raising the sights

Don't damn ISO14001 if participating sites don't outscore the pack on environmental compliance. Acknowledge instead, says SITA's Gev Edulgee, how the formal EMS has helped spread the compliance culture. Across the board.

You might expect that sites with formal, certified environmental management systems (EMSs) would have better compliance records than sites with no EMS. Well, they don¹t ­ says a recent study by the Policy Studies Institute (PSI).

This must have brought out smiles in the boardrooms of companies looking to cut non-productive overheads ­ and had compliance managers reaching for their smelling salts. One commentator called it "a serious blow to the credibility" of formal EMSs such as ISO14001. What is the point of them, if they offer no discernible improvement in environmental performance? But the PSI study can be viewed in a different, much more positive light. Companies without formal EMSs may be no more likely to disregard their legal environmental obligations ­ but why expect otherwise? That is to misunderstand the main driver for compliant behaviour.

Operating compliantly, like observing health and safety procedures, is a state of mind inculcated into site workers and managers through their vocational training and through the example of their peers. Rising levels of training and environmental awareness over the past decade have raised awareness of its importance ­ with or without an EMS. Rather than ISO14001 failing to deliver better performance, the overall culture of compliance is rising to the level of the better performers. ISO14001, together with employee training, holds this top line ­ reinforcing and formalising the culture, in the way that a speed camera, by its very presence, prompts the habitually recalcitrant driver into obeying the law.

Any quality-conscious company plans the manufacture of its products meticulously, and codifies these steps in a set of procedures and targets. Managing the environment requires no less attention to formality and to codification. A common EMS and a common language enable firms to benchmark their performance against their competitors. More importantly, where an ad hoc approach is likely to stress legal compliance as the ultimate goal, an EMS can treat it as a minimum performance standard. Combined with environmental reporting, it offers a robust basis for greater self-regulation. ISO14001 raises the sights of management from the feet of the company to the horizon ­ and operating in the public eye is perhaps the single most potent lever for change.

The 'zero defect' trap

It's fine for quality assurance, under ISO9001, to be based on a Ozero defect¹ standard, but the transfer of this ideology to ISO14001 is less appropriate. While 100% customer satisfaction is a reasonable objective for improving the quality of products and services, achieving and maintaining 100% environmental compliance is more complex. Even the best run companies face residual ­ historic or 'structural' - non-compliances which can only be remedied over the longer term.

Landfill sites, for example, might remain technically non-compliant until gas or leachate management systems have been designed, engineered and installed, requiring significant resources and perhaps taking many years over a company's portfolio of sites. There is no magic solution, other than acknowledging such problems and working with the regulator to resolve them over an agreed timeframe. But scoring them as non-compliances on the Environment Agency's Operator Performance and Risk Appraisal (OPRA) database creates a backdrop of continuing bad OPRA scores, regardless of successes in rectifying non-compliances resulting from day-to-day operations and failures in management systems.

By using OPRA scores that do not differentiate between 'structural' and 'operational' non-compliances, the PSI study may have masked efforts to improve day-to-day performance, and underestimated the impact of an EMS in influencing change.

Gev Eduljee is technical director of SITA

1 February 2003

Gev Edulgee