With the possible exception of climate change, no subject is more visible in environmental circles today than the quest for a scheme to compare the environmental performance of organizations. Major initiatives in both the private and public sectors (e.g., USEPA's Performance Track, the Eco-Management and Audit Scheme [EMAS] in Europe, the Coalition of Environmentally Responsible Economies [CERES], the Global Reporting Initiative [GRI], and many others) all seek to elicit voluntary disclosures from organizations that would enable the public and others to make environmental comparisons so as to separate the sheep from the goats, in a manner of speaking. While admirable for their persistence, these initiatives raise at least three questions in my mind:
- Is it likely that organizations will voluntarily provide the detailed information that would be needed to attempt such comparisons?Even if all the information needed were made available, would it be possible to actually compare organizations (i.e., compare apples to apples)?
- Finally, even if we could compare the environmental performance of plants, how important would such rankings be to downwind neighbors?
The answer to the first question is no, not likely. Why not? There are two main reasons organizations will not voluntarily provide detailed environmental information-legal repercussions and business confidentiality. The system for environmental care in the United States and in most other countries is based on compliance with and enforcement of governmental regulations. The regulated entities are given operating permits that specify allowable and presumably tolerable levels of pollutants in their emissions, effluents, and shipments. Those permits also oblige those entities to disclose various details of their environmental status and performance. The legal ramifications of those disclosures can be very severe if they show excursions from allowable limits. In fact, the environmental statutes provide for onerous burdens of liability including the strict, retroactive, and joint and several varieties. Additionally, they allow citizen suits, whereby private parties can self-deputize to bring legal actions in place of the enforcement officials, even when those officials have exercised their discretion not to pursue legal remedies. Furthermore, any voluntary disclosures above and beyond those mandated by permits would trigger the same legal exposures. What is the likelihood, therefore, that an organization would voluntarily increase its legal exposures by disclosing sensitive information it is not obligated to disclose? Not very likely, I believe.The information that organizations would need to disclose to allow a reasonably accurate comparison would necessarily have to be detailed and much broader than just on levels of pollutants. Comparability implies that pollutant levels from different facilities should be normalized for the operating characteristics, quantities of materials used and products made, levels of technology, availability and use of resources, and many other factors. Only in this way could we even approach the goal of comparing apples to apples. But, how likely is it that organizations will disclose those details that can give away confidential information to a competitor? Once again, not very likely, I believe.The answer to the second question is also no, I fear; at least, not in terms of an overall rating for the organization. We may compare VOC emissions per unit of production and that may have some validity. But, how do we combine VOC, CO2, NOx, energy consumption, hazardous waste, BOD, etc., into one meaningful measure that tells us which organization is performing better than another overall. The problem, aside from the challenge of normalization, is that we have not yet invented a unit of measure for pollution. One unit of CO2 is not the same as one unit of NOx or one unit of BOD. As I've stated in this column before, unlike the situation in the financial world where money is the standard measure for inventory, accounts receivables, profits, revenues, etc., there is no single standard to measure across all pollutants. Any scheme to make comparisons will inevitably run up against this reality. In the final analysis, it becomes impossible to rate facilities relative to each other except in cases where one facility is "worse" than another in all categories. But even then, what if the facility that is polluting more in every category is still in compliance with its permits and the reason it is polluting more is because its technology is older but not yet old enough to be replaced? Is it fair to imply that the management of this organization is less responsible? Is it reasonable to pressure this facility to speed up modernization when it can still get useful and profitable service from its existing plant?The final question asks whether neighbors really care about the relative industrial ranking of a facility located in their neighborhood. It seems to me that they would be much more interested in the compliance history of that facility. They would be interested in the attitude and sincerity of its management. They would care about the procedures, programs, and systems the facility has implemented to avoid incidents. I believe that a facility would have little to brag about if it received low grades in these areas from its neighbors even if it did rank high within its industry. Ultimately, neighbors are less concerned with industry rankings than they are with risk-risk to their health and degradation of their quality of life. What comfort is it to a family that the plant next door is in full compliance and ranks high within its industry as a clean producer if the emissions from that plant have a measurable impact on the family's health and well-being? They care most about gross emissions from that plant and the possible consequences of those emissions to them. Conversely, the most important interested party for the plant is the neighbors that may be impacted by its operation. These neighbors need to be kept informed of environmental matters that affect them, not of industry rankings that have little meaning and can be easily manipulated.
As we move forward with proposals for an environmental communications document in ISO/TC207, we should keep some of these ideas in mind. The important objective is to communicate relevant, useful information to parties that really care, in ways that are understandable so that appropriate measures may be taken to protect them. It would be a waste of time and resources and ultimately futile to focus this document on comparability. There are simply too many impediments-legal and commercial-and too many scientific and technical problems to overcome for comparability to be a viable proposition. Worse yet, it would not help any of those living downwind and most concerned.
Every time a U.S. president completes his final term, there's a certainty that the federal government will undergo a transition to a new administration. Since a two-term limit for the president was made a Constitutional amendment, only three presidents have completed two terms in office: Dwight Eisenhower, Ronald Reagan, and Bill Clinton (assuming nothing unexpected between now and January 20, 2001). There have been other transitions due to presidential defeats, but a second term gives the federal government more time to think about and prepare for the changes.As I write this column, the identity of the president-elect is still uncertain. Whether Governor Bush wins or Vice-President Gore wins, the federal government is going to change. New Cabinet secretaries will be nominated, new agency administrators will be appointed, and the Senate will have to deliberate confirmation of nominees as well as its legislative agenda. As the new leaders take their places in the months ahead, they will bring new priorities, new ideas about how things should be done, and, in all likelihood, new enthusiasm. This is part of the natural change in American politics. After all, one pundit was known to have observed that "politicians are like diapers and should be changed frequently, usually for the same reason."Now, what does this have to do with quality? During the past eight years, quality practices have gained a stronger foothold in federal government operations. A Number of federal organizations have attained certification to ISO 9001 while others have implemented Baldrige-like programs in their operations to achieve improvements in quality and efficiency. Recently, the Federal Acquisition Regulations (FAR) were changed in 48 CFR 46 to allow federal organizations wider latitude in selecting quality requirements for procurements. This flexibility allows, for example, the U.S. Environmental Protection Agency to use the American National Standard ANSI/ASQC E4:1994 as quality criteria for contracts involving environmental data collection or environmental technology development. At the same time, the Department of Defense may invoke ISO 9001 for any of its procurements.In addition, there is mounting evidence that the federal government has begun to grasp the fundamental concepts of quality assurance and is beginning to move beyond quality control toward effective quality management practices in many areas. There are increased efforts to harmonize quality practices and procedures among federal organizations. For example, the Inter-Governmental Data Quality Task Force (IDQTF) is developing guidance on implementing the requirements of ANSI-ASQC E4 uniformly across environmental programs in several federal departments and agencies. These efforts have shown great promise for reducing workloads and simplifying practices in environmental programs.Last spring, the White House issued Executive Order 13148 to implement environmental management practices throughout federal agencies. Among several requirements pertaining to compliance, pollution prevention, and reductions in ozone-depleting substances, is a requirement that all federal agencies develop and implement an environmental management system (EMS) at all appropriate facilities by December 31, 2005. As federal organizations move to comply with this order, they'll be putting into effect many of the underlying principles of quality management as well, which should help in implementing more quality management systems at the same time.As the federal government makes its transition to the first presidential term of the 21st century, let's hope that the momentum toward more effective quality management practices is not perturbed in any way. Quality must be a key element in all aspects of the federal government if services are to be maintained and effectiveness is to be improved. It would be wonderful if the next president issued an executive order requiring all federal organizations to implement a quality management system. It could happen, but the path is likely to be a slower one. As the new leadership steps into place across federal organizations, there's a challenge to quality professionals to ensure that the new people are educated on the value and benefits of quality management to their missions. We cannot assume that the new management teams even will be "quality-literate." We must show them and teach them and help them to accept and embrace quality management with the same commitment and enthusiasm exhibited by business leaders worldwide.As Frank Collins said before, "The ball is in our court." As the federal government makes its transition to a new administration, we must work to make it a transition to quality.