Select Committee on Environmental Audit Minutes of Evidence

Memorandum submitted by The British Standards Institution

1. INTRODUCTION

  This written submission has been prepared in support of the oral evidence provided by the British Standards Institution (BSI) at the Environmental Audit Committee's Inquiry into the Greening of Government on 6 May 1998. This document covers the following topics:

—  Background to the British Standards Institution (BSI).

—  The emergence of management systems standards.

—  The history of environmental management systems standards and related work.

—  The key requirements of ISO 14001: 1996 Environmental management systems—Specification with guidance for use.

—  The differences between ISO 14001 and the European Commission's Eco-Management and Audit Scheme (EMAS) Regulation.

—  The current revisions of ISO 14001 and EMAS.

—  The business benefits of environmental management systems (EMS).

—  The application and relevance of EMS to Central Government.

—  Comments on the Department of Transport and the Regions (DETR) survey of EMS implementation and certification by Government departments.

—  The way ahead for central government—some thoughts and observations.

  In addition to the topics covered in the main document a number of appendices have been included, including case studies of EMS implementation and certification in the public and private sector.

2. WHAT IS BSI?

  BSI was the world's first national standards body, formed in 1901 to ensure minimum standards in product manufacture and design. It was incorporated by Royal Charter in 1929 and has grown to become the most respected standards body in the world. BSI has a membership of more than 30,000 businesses and organizations and operates in some 140 countries world-wide. BSI represents UK interests in the International Organization for Standardization (ISO), the International Electrotechnical Committee (IEC), and the European standards-writing bodies (CEN and CENELEC).

  BSI manages the UK technical committees which produce British Standards and represent UK plc during the development of European and International Standards. These technical committees (TCs) comprise some 28,000 members from industry, consumer groups, Government departments and agencies and other interested parties. BSI staff provide the secretariat to these committees and to some of the committees in ISO, IEC, CEN and CENELEC.

  In addition to the management of standards-writing BSI also undertakes a number of commercial activities, including:

—  The assessment (auditing) of clients management systems to ensure that they comply with the requirements of standards including ISO 9000 (quality management systems), ISO 14001 (environmental management systems) and BS8800 (occupational health and safety management systems). As part of this assessment process it has always been BSI's aim to promote the use and dissemination of industry best practice and to improve the performance of UK companies in order to make them more efficient and competitive in the global marketplace.

—  The testing of products against pre-defined contract, legal, performance or design criteria. This testing activity may be to determine the quality or safety of a product, its conformity to a contractual specification, or the environmental impacts associated with its manufacture (e.g., for eco-labelling purposes).

—  The award of product conformity marks against products which have been tested to either a full-blown British Standard or a Product Assessment Specification (PAS), which is effectively a fast track standard. This testing and marking activity allows companies to demonstrate the safety and quality of their products to their stakeholders. The most familiar product mark in the UK is the Kitemark, which enjoys 82 per cent brand recognition from consumers.

—  The training of clients in the core areas of BSI's standards-related activities. For example, BSI runs a number of training courses in the following areas:

  —  Quality management systems and quality assurance.


—  Environmental management systems and environmental auditing.


—  Environmental performance indicators and environmental reporting.


—  Occupational health and safety management systems and auditing.


—  The Business Excellence Model.


—  Business Process Improvement.


—  Project management.


—  Risk assessment and management.


—  Information security management.

—  Electronic software products to support the development, implementation and maintenance of management systems.

—  Publications, handbooks, guidance documents and videos.

3. A BRIEF HISTORY OF MANAGEMENT SYSTEMS

  As well as playing a role in ensuring internationally workable standards BSI has been at the front of standards making aimed at delivering internationally agreed levels of quality using systems-based approaches. The most successful of these to date has been the ISO 9000 Series of international quality management and quality assurance standards. These standards encourage companies to establish management systems to measure and monitor "total quality management" from staff development to improved product/service quality in order to improve market competitiveness and profitability. Companies can have their quality management systems validated by a third party against the requirements of these standards and are awarded a certificate if their systems meet these requirements. Gaining a certificate gives the company the right to claim that they have achieved a level of quality management which is internationally recognised. In the UK, Government played a leading role in promoting the adoption of quality management systems by industry, allowing UK companies to qualify for international tender lists ahead of international competitors.

3.1 ENVIRONMENTAL MANAGEMENT STANDARDS—THE ISO 14000 SERIES

  In 1993, following the success of the ISO 9000 Series standards and recognising the need for internationally accepted standards for environmental management, ISO began development work on a new series of standards which assess and monitor the environmental performance of organisations. These standards provide the framework and technical content for the development and maintenance of environmental management systems, environmental auditing programmes, environmental performance evaluation, the life cycle assessment of products and the award of eco-labels against products meeting eco-labelling criteria. These standards have come to be known as the ISO 14000 series after the numbering allocated to them by ISO.

  The first five of these standards dealing with environmental management systems and environmental auditing were published in the last quarter of 1996. A number of other standards dealing with eco-labelling, life cycle assessment and environmental performance evaluation are now also publicly available.

4. ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEMS—SPECIFICATION WITH GUIDANCE FOR USE

  ISO 14001 forms the cornerstone of the ISO 14000 series of standards, it offers businesses the framework for effective environmental management through the establishment of an environmental management system.

  It specifies the requirements for an environmental management system (EMS) against which organizations may be certified by appropriately accredited third party certification bodies.

  The specification requirements for an EMS under ISO 14001 include the:

—  gaining of top management commitment to the EMS;

—  development of an environmental policy;

—  planning of an EMS including the:

  —  identification of signficant environmental aspects and their associated environmental impacts;


  —  establishment of legal and regulatory requirements relevant to the organizations activities, products and services;


  —  development of quantifiable objectives and targets to reduce the organization's significant impacts on the environment;


  —  establishment and maintenance of environmental management programmes, which include the proper allocation of resources and specified timeframes within which to achieve stated objectives and targets.

—  implementation of an EMS, including:

—  the development of training and awareness programmes;


—  the allocation of roles and responsibilities within a predefined management or organizational structure;


—  procedures and processes for handling internal and external communications;


—  the creation of supporting documentation and documentation control mechanisms;


—  operational control procedures; and


—  emergency preparedness and response planning and testing.

—  maintenance and continual improvement of the EMS, including:

—  the monitoring and measurement of operational activities;


—  record-keeping;


—  the creation of procedures to deal with non-conformances with the requirements of the Standard, company policy and legislation;


—  the development of procedures, programmes and processes to prevent any repeat of non-conformances; and


—  EMS audit procedures and programmes.

—  management review of an EMS to determine its suitability, adequacy and effectiveness and to make recommendations to achieve continual improvement.

  The primary aim of all of the above is to ensure that the company can demonstrate continual improvements in its overall environmental performance in line with legislative requirements, corporate environmental policy and the objectives and targets it has set itself.

4.1 THE RELATIONSHIP BETWEEN ISO 14001 AND EMAS

  There are a number of key differences between ISO 14001 and EMAS which arise from the fact that the two EMS models were developed in different fora, at different times for different reasons. Whilst ISO 14001 offers an internationally accepted model for an EMS, EMAS includes requirements not just for EMS but also includes the implementation of audit programmes and the requirement for a public environmental statement. The key differences between ISO 14001 and EMAS are summarised below:

—  EU Eco-Management and Audit Schemes (EMAS):

—  public environmental statement required, describing the site to be registered and its environmental performance;


—  EMAS is site-specific, it is not possible to register a whole organization only one site at a time;


—  EMAS currently only applies to manufacturing industry and the power generation, quarrying and mining and waste management sectors;


—  EMAS does not include explicit requirements for prevention of pollution or emergency preparedness and response.

—  ISO 14001:


—  contains no mandatory reporting requirement, it merely requires the organization to consider external communication and record the decision it makes or whether to or not (although many companies do publish an environmental report);


—  registration may be applied to the individual site or company-wide;


—  applies to all industry sectors, including the service industries;


—  includes a commitment to prevention of pollution and emergency preparedness and response.

It should be noted that it is possible to achieve both ISO 14001 and EMAS at once, using the so-called CEN "Bridging Document". For further details on the relationship between EMAS and ISO 14001 please see the BSI EMS Handbook which has been included with this submission.[4]

4.2 THE CURRENT REVISIONS TO ISO 14001 AND EMAS

  At present the two management systems models are subject to a review. At the next ISO/TC 207[5] meetings in San Francisco a proposal to commence the review of the EMS and environmental auditing standards one year early has been put forward for consideration[6].

  The ISO 14000 series revisions include proposals for:

—  including Initial Environmental Review (IER), the baseline data gathering associated with developing an EMS, within the specification in ISO 14001;

—  mandatory environmental reporting as part of the clause on Communications within ISO 14001:

  —  including possibility of a separate international environmental reporting standard;

—  integrating ISO 14010-12 (the environmental auditing standards) into one standard and adding clauses on "joint" audit programmes to allow for the simultaneous auditing of quality and environmental management systems.

  EMAS is also currently subject to revision including radical proposals for:

—  inclusion of all industrial sectors within the scope of EMAS (including the service sector);

—  changes to composition of the public environmental statement to allow for the publication of non-technical "sub-statements" as well as technical statements for verification purposes;

  —  one proposal also allows for the inclusion of product information in the statement, although it is unclear as to how this information may relate to the European Regulation and Eco-Labelling;

—  international EMAS registers and competent bodies, thus extending the geographical coverage of EMAS beyond the boundaries of European Union Member States;

—  a review of the verification framework and supporting guidance documents, possibly involving a one year validation period (not three years as at present);

—  the use of ISO 14001 (unchanged) as the EMS element of EMAS.

  The result of both of these revision processes is likely to be two EMS models which look remarkably similar, with the same sector and geographical coverage. This may in the future pose the question "Why do we need two EMS models?"

5. THE BUSINESS BENEFITS OF ENVIRONMENTAL MANAGEMENT SYSTEMS

  Generally speaking the business benefits of ISO 14001 may be broken down into the two main elements: clear and tangible financial benefits and less tangible benefits which are hard to allocate a financial angle. The tangible financial benefits may be broken down into the following categories:

—  achieving cost-savings by reducing raw material and energy usage through the identification of waste minimization opportunities and process redesign;

—  identifying alternative "cleaner" manufacturing processes, techniques and materials;

—  avoiding the unexpected costs associated with regulatory enforcement through improved legislative compliance;

—  improved access to external ethical/environmental investment funding and internal corporate funding;

—  access to investment finance for major infrastructure projects (the European Bank for Reconstruction and Development, the European Investment Bank and the World Bank now recognise ISO 14001);

—  acting in a proactive manner to minimize exposure to environmental liabilities, thereby improving the insurance policy conditions and obtaining reduced insurance premiums;

  The less tangible benefits of ISO 14001 may include:

—  enhancing corporate environmental image, meeting consumer expectations and thus improving market share;

—  achieving competitive edge by getting ahead of the competition and meeting supply chain requirements for ISO 14001;

—  improving internal communication and relations with staff members and contractors and external relations with the local community, the general public, regulatory bodies and government at every level;

—  enhanced staff awareness of environmental issues, often leading to shopfloor suggestions for process improvement, improved operating efficiencies and ultimately profitability;

—  increasing the likelihood of successful planning applications and pollution control consents and permits.

  In the appendix to this document are case studies of how some companies have achieved significant business benefits from implementing ISO 14001. The examples of cost-savings which many companies have experienced are often very impressive, with one company achieving 48.3 per cent energy savings in the year following EMS implementation. Further case studies and information are available on BSI's website at http://www.bsi.org.uk.

6. THE APPLICATION AND RELEVANCE OF EMS TO CENTRAL GOVERNMENT

  Local government has been using environmental management systems to improve their environmental performance for a number of years and a pilot project under EMAS: Local Authority EMAS (LA-EMAS), has been in operation since April 1995.

  Generally speaking the business benefits for local government have been the same as for the private sector; although the emphasis and objectives of EMS implementation in local government are often subtly different. In addition to achieving cost-savings and motivating staff, local government use EMS as a tool:

—  to develop and drive Local Agenda 21 initiatives;

—  for the environmental appraisal of local and regional plans; and

—  for the determination of environmental impacts associated with the provision of local government services (so-called "service effects").

  Central Government should now be actively promoting the adoption of EMS for the following reasons:

—  Industry is leading not Government. Despite a number of policy statements from the Secretary of State for the Environment, Michael Meacher, "encouraging" industry to adopt environmental management systems and promoting the benefits of a systematic approach, central government, on the whole, is not practising what it is preaching. It needs to do so to retain its credibility with the private sector, particularly in the light of Commitment No.373 of the 1995 report This Common Inheritance, which publicly committed the government to assess the practicality of implementing environmental management systems in its departments and agencies.

—  Central government should look to achieve some of the cost-savings associated with EMS implementation in the private sector. Savings attributable to good energy management and waste minimisation will optimise the use of public money within government departments and agencies.

—  "If it gets measured it gets done . . . ". All organisations, including central government departments and agencies, can only set targets to improve their environmental performance if they understand where their environmental impacts lie—be they direct impacts, service impacts or impacts arising from policy-making.

—  The third party validation of environmental management systems provides the credibility central government needs to satisfy the broad range of stakeholders they communicate and interact with. Whilst there may be a number of greening initiatives within government departments third party registration to ISO 14001 or EMAS demonstrates commitment to all stakeholder groups.

—  By establishing common environmental performance indicators (EPIs) against which to monitor and measure environmental performance and progress against the targets set within an EMS it is possible to benchmark the environmental performance of different government departments and agencies against each other.

—  When adopted, a draft European Directive on Strategic Environmental Assessment (SEA) will require government departments and agencies to undertake environmental appraisals of ALL their policies, plans and supporting activities. Government departments should implement EMS as a more strategic tool to enable them to measure the outputs and impacts of the policies and plans they produce. Used in this way EMS can be used as a scenario-building tool to assess the best environmental option for all policy-making and planning activity within government.

—  Environmental management systems provide an ideal opportunity for government to green the supply chain at little or no cost. By specifying ISO 14001 or EMAS as a requirement for its own green procurement drive government has the ability to green the supply chain using a voluntary initiative, rather than relying on further environmental legislation to achieve the same policy goal. A more flexible approach to environmental performance improvement may well prove highly popular!

—  ISO 14001 and EMAS may be used as a framework tool for implementing policy, e.g., national communications under Kyoto Protocol. Here monitoring and measurement frameworks, including legislative requirements, may be gathered under the framework of an EMS and analysed according to policy requirements or the requirements of international agreements.

7. COMMENTS ON THE DEPARTMENT OF TRANSPORT AND THE REGIONS (DETR) SURVEY OF EMS IMPLEMENTATION AND CERTIFICATION BY GOVERNMENT DEPARTMENTS

  The fact that only two government departments have been certified to ISO 14001 to date is obviously disappointing, especially given that three years have passed since the publication of This Common Inheritance. Although there are a number of other government offices implementing ISO 14001 at present, those actively engaged in EMS implementation represent a small percentage of UK government offices.

  It is encouraging to see a healthy uptake of ISO 14001 in the healthcare sector, spurred on no doubt by the availability of the GREENCODE software and publications package—a sector-specific guidance package. However, it is interesting to note that most of the NHS Trusts implementing ISO 14001 or using GREENCODE are in Scotland and Northern Ireland, with no mention of participating English or Welsh NHS Trusts.

  The benefits of EMS implementation described in the DETR survey are similar to the benefits commonly quoted in the private sector. However, the barriers to implementation quoted in the survey are rather "old hat" and smack of middle management inertia more than factual reasons as to why an EMS has not been implemented. EMS implementation does require investment but we find our clients are often able to demonstrate that the benefits, including financial benefits, outweigh the costs of EMS implementation (see Appendix for case studies) and that payback periods are often very short—in many cases payback is achieved in less than six months. Profitability and sustainability can go hand-in-hand. As to "lack of resource" BSI has registered a range of small companies to ISO 14001 (the smallest company we have registered has only six employees). Proving that resources really shouldn't be an issue if management have the will to achieve certification.

  ISO 14001 is equally applicable to the service sector as it is for the manufacturing sector. In the financial year 1997-98 11 per cent of BSI's ISO 14001/EMAS registrations fell within the service sector, including a number of local authorities and agencies, such as the London Borough of Sutton, Nottingham City Council and Dundee City Council.

  Finally, a comment on the consultants report on ISO 14001 implementation and certification within the Ministry of Agriculture, Fisheries and Food (MAFF). This report quotes an implementation cost of £397.4K, with £491.6K in first year running costs. This figure seems extraordinarily high! No organization would implement an EMS with such prohibitive costs. Unfortunately, this figure is not broken down into the component parts for EMS implementation and certification but one suspects that the bulk of the figure quoted relates to the consultancy costs of EMS implementation with little or no direct involvement of MAFF employees. This is not the most cost-effective method for establishing and maintaining an EMS. The solution is to train and motivate internal "champions" and build the EMS using your internal knowledge of the organization to reduce implementation time and costs.

  The certification costs of ISO 14001 should be small by comparison. For example, BSI's certification of the Scottish Office's building at Victoria Quay in Edinburgh cost just £6.7K, including the first year's continuing assessment work. This site covered 2.75 hectares with 1,100 employees.

  The recommendations of the report are very clear and make good business sense. The two key stumbling blocks for any organization are understanding the environmental legislation that applies to it and where the significant environmental impacts lie in its business activities (and how to address them). In particular, we would suggest the establishment of an EMS training programme at the Civil Service College focusing on EMS implementation and auditing, preferably using the syllabi produced by the Environmental Auditors Registration Association (EARA). There are a number of organizations, including BSI, who have a range of EARA accredited training courses which may be purchased on a training license agreement basis. By using the Civil Service College as the centre of excellence for EMS training it may also be possible to develop Fast Track graduate civil servants as the EMS champions for the various Government departments.

8. THE WAY AHEAD FOR CENTRAL GOVERNMENT—SOME THOUGHTS AND OBSERVATIONS

—  Develop a centre of training excellence at the Civil Service College to reduce external training costs and utilise Fast Track Civil Servants as internal EMS champions by providing them with basic EMS training as part of the Civil Service College programme. This will facilitate EMS implementation within Government departments and allow for the development of a body of environmental knowledge within Government, reducing the need for external consultancy.

—  Learn by your successes and mistakes: pilot ISO 14001 or EMAS in key government departments and agencies (e.g., DETR, DTI) and disseminate.

—  Consider integrating ISO 14001 or EMAS with existing management systems, e.g., quality or health and safety to form one management system.

—  Even if management systems are not fully integrated, look to certification bodies capable of offering integrated management systems assessment for environment, quality and health and safety. Integrated assessments will reduce the number of management "down" days as one assessment covers all the necessary audit areas, rather than having three separate assessments for quality, environment and health and safety.

—  Develop a database of key legislative requirements for government offices available to all on secured intranet or internet servers.

—  Develop a common, generic approach to environmental impact assessment and significance rating. This will save a lot of time and prevent different government departments from re-inventing the wheel.

—  Where appropriate, consider the use of EMS software solutions—they can reduce implementation time by up to 30 per cent.

—  Look at using EMS as a legislative implementation tool in industry, e.g., for the Integrated Pollution Prevention and Control (IPPC) Directive and the Control of Major Accidents and Hazards (COMAH) Directive, where a business-wide approach is appropriate.

—  If any form of consultancy on EMS implementation is considered necessary use the buying "clout" of combined government departments to deliver economies of scale for consultancy services.

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4   Not printed. Back

5   The ISO technical committee responsible for managing the ISO 14000 Series standards. Back

6   This proposal is to align the revision cycles of the ISO 14000 series standards with the current revisions of the ISO 9000 quality standards to allow for the ongoing compatibility and possible integration of the two series of standards. Back

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Prepared 1 July 1998