ASQ - Energy and Environmental Division

The recently enacted Eco-Management and Audit Scheme II (EMAS II) in the European Union (EU) incorporates ISO 14001 to satisfy the environmental management system (EMS) requirements of that regulation. While this incorporation is an acknowledgement by the EU Commission of the validity of ISO 14001, it is also an unavoidable recognition that ISO 14001 is the hands-down favorite EMS among European companies. As of January 2001, 10,041 facilities were ISO 14001 certified in the EU whereas only 3,809 facilities were EMAS registered there.

In the 1993 to 1996 time period leading up to the release of ISO 14001, two counter predictions were often voiced by representatives from the EU and the United States, respectively:

  • ISO 14001 would not be acceptable in Europe, and EMAS would dominate.
  • EMAS would disappear as the advantages of ISO 14001 became recognized.

    As it turns out, both sides were only partially correct in their assessments. While EMAS does not dominate in the EU, it clearly has not disappeared. Given these results, it is instructive to understand what is behind the Numbers and why EMAS is still a player when ISO 14001 is so obviously preferred.

    First, why is EMAS touted in some countries as being superior to ISO 14001? Primarily, it is because of various provisions that are seen to promote higher environmental performance and, therefore, greater compliance with regulatory requirements. For example, EMAS requires

  • continuous improvement of environmental performance, not just of the management system;
  • an initial comprehensive analysis, not just a selection of significant environmental aspects;
  • the publication of an environmental statement of significant environmental issues with quantified emissions, effluents, waste and energy use, not just consideration of whether or not to do external communications;
  • an independent verification of the environmental statement (not applicable
    with ISO 14001); and
  • an approval by the enforcement authorities, which is conditioned on the compliance status of the company (not applicable with ISO 14001).

    By contrast, the attraction to ISO 14001 is attributable to its flexibility and ease of use. Its advantages to implementing companies include

  • a clear structure for the EMS,
  • no involvement of public bodies,
  • no additional expense of verification, and
  • worldwide recognition.

    Because of the perceived advantages of ISO 14001, experience shows that when governments accord equal treatment and benefits to EMAS and ISO 14001, companies will overwhelmingly choose to implement the latter. Only in countries that offer exclusive benefits for EMAS implementation do we find substantial Numbers of EMAS adoptions. In Germany and Austria, where companies are offered financial incentives and regulatory flexibility for EMAS implementations, EMAS and ISO 14001 adoptions are evenly split. Germany and Austria account for 2,972 of all EMAS registrations in the EU. In countries where no financial or regulatory advantages are provided for EMAS, ISO 14001 clearly dominates the scene. Of all the ISO 14001 advantages, those cited most frequently are those of lower cost of implementation/certification and worldwide recognition.

    The question then is, “Why don’t all EU countries offer special recognition for EMAS given that in some circles it is considered a superior EMS?” Why in fact do they mostly accord equal treatment to EMAS and ISO 14001? The answer seems to be that either EMAS or ISO 14001 (and for that matter any standard EMS) implementation leads to improved environmental performance across the board, including greater compliance with regulatory requirements. In effect, EMAS does not appear to produce better results than ISO 14001. Recent empirical evidence from Europe and elsewhere seems to support that conclusion, and it is one of the reasons EU countries have not generally accorded greater weight to EMAS.

    There are, to be sure, many other policy reasons why EU countries do not offer benefits simply for having an EMS. In the Netherlands, for example, an EMS is only one element of a batch of requirements that a company must satisfy before being considered a proactive company that may qualify for regulatory relief. There, as in most other EU countries, no distinction is made as to whether the EMS is based on EMAS or ISO 14001. Showing a clear preference of industry for ISO 14001, Holland had 26 EMAS registrations and 800 ISO 14001 certifications as of January 2001.

    In short, it appears at this point that EMAS is still a factor in the EU only because of special treatment in some countries. ISO 14001 is otherwise the clear choice of industry, both because of its greater clarity and lower cost, and because in the end it appears to deliver as much environmental performance and regulatory compliance as EMAS. And this is something that we all can be happy about.

    There has been a lot of discussion lately (in the halls and around the water cooler) about management system integration. It sometimes sparks a passionate response among employees, both for and against integration. But the basic question still remains–is system integration really being done successfully anywhere, or is it simply something that a lot of folks are talking and worrying about but few are implementing?

    When asked about this by my clients, and whether I see anyone trying full, or even partial, integration, I often point back to 1988–1989. During that timeframe, I was frequently asked if this “ISO 9000 thing” was really going to take off or not. The big multinational companies were implementing ISO, but were any others bothering? Some companies felt it was a “European thing,” required only if you wanted to do business overseas. Others felt it was simply the next in a long line of the latest quality fad and something without lasting impact. My perception now is that we are in a similar situation today to a large extent, not for the ISO 14001 implementation per se, but for the integration of 14001 with other management systems (most notably, ISO 9001:2000). Many companies are questioning whether they will actually integrate their systems or not.

    Many consultants (including me) feel that we have a great opportunity to integrate at least portions of the two systems. There are requirements for management review, document and data control, internal audits, and records control, which can be integrated fairly easily. Management review, although requiring similar elements, also has some compelling arguments against integration–that of time. It is sometimes difficult enough to get all the key senior executives together for a meeting without making the meeting longer (and therefore more difficult to schedule) by covering both systems at the same meeting. So although the concept may be sound, the implementation can be strewn with roadblocks.

    Another argument against integration comes when determining if auditing can be integrated. It is a common expectation that auditors should have a background in the system that they are auditing. Just as it is important for a quality auditor to know where to find the latest specs, drawings, and operator instructions, it falls on the environmental auditor to be aware of how to find the latest in the national, regional, state, and local regulations. Folks have strong opinions on whether an auditor from one of these disciplines will automatically make a good auditor in the other discipline. Whether you are for or against dedicated auditors, I think there is universal agreement that all auditors need to be fully aware of the requirements of the standard, the requirements of other sources (such as customer inputs, regulations, and laws), and what the process approach to management systems auditing means.

    With the Big Three and other large companies, such as IBM, requiring their suppliers to pursue ISO 14001 as part of supplier development, the question is not, “Should we implement ISO 14001” but “When?” Once this decision to implement has been made, the next question becomes, “Should we integrate? If so, how much?”

    Although the subject of degree of integration is too large to handle here (in our forthcoming book, the other authors and I devote an entire chapter to this discussion), I can state that although we all come from different backgrounds, we all strongly believe that integration is the way to go. In today's marketplace and economy, there's no room for turf wars on common elements like documentation control and records control; there's too much work and not enough employees to maintain these systems separately as it is! In addition, there are other savings that can be realized if companies choose to integrate, including a more knowledgeable workforce (an operator now may see a focus on the entire job, rather than a focus on reducing pollution, a separate focus on improving quality, and perhaps a third or fourth focus (health and safety, company initiatives, etc.).

    As a subcontracted registrar auditor, have I seen integrated systems? Yes, some. Are they fully or partially integrated? Both. Have I seen totally separate systems? Yep, seen some of those also. So what's the right answer?

    The question should not be “What's the right answer?” but rather “What’s the right answer for my company?” Some companies have fully integrated their system, and it works for them. Others have found that partial integration works well for them, because other areas of the management systems are dealt with separately by dedicated personnel who have an expertise in one, but not both, of the systems being integrated. Still others are keeping them separate (for now). All systems have worked to date, but as companies are trying to implement continual (cycles of) improvement, they will need to address
    whether their company would not be better served by partial or full integration.

    If you are one of the employees trying to decide which way to go, I would again recommend at least partial integration of the system to avoid duplication of effort and achieve economies of effort. Integration of the two management systems may be on the far horizon for you, or may be imminent; either way, take the time to carefully consider what degree of integration is right for your company.

    What's your opinion? Drop me a note at isoqsinc@aol.com.

    We are now more than six months into the new George W. Bush Administration and the direction of quality and environmental policy is still unclear. Most federal departments and agencies now have their top-tier political appointees in place, and many have the majority of the second-tier managers named or confirmed. At EPA, for example, most of the program office assistant administrators have been named, but only about half of the regional administrators have been selected.

    What this means is that little real change is happening in federal organizations. Life is largely a continuation of what was done before. We call this the “bureaucratic flywheel” effect, and it religiously obeys Newton's first law on inertia. Thus, it will be some time yet before the full impact of new political leadership is felt on day-to-day operations.

    So, where are we right now relative to the new administration? The answer seems to depend on who’s talking. For the Energy and Environmental Division, there would appear to be hope that the Bush Administration's largess to the energy industry to the tune of some $34 billion in tax breaks would sound a renewed interest in energy production and distribution. Certainly, the power woes in California and other western states this spring would seem to support that conclusion as well. The question is, “Are there any quality issues there?” The current emphasis is on the construction of gas-fired turbine generating plants. To date, though, I haven't seen evidence of any commitments to large fossil or nuclear generating units. In any case, the technology appears to be well developed, and one has to wonder if quality is really an issue for EED or is it an issue for design and construction. To be honest, the nuclear power sector has been dormant for so many years that you may ask legitimately if there still is a viable nuclear steam supply system (NSSS) vendor remaining in the United States. Can EED realistically expect the doldrums of the past decade to suddenly disappear and a new wave of excited, quality professionals from the energy industry to beat a fast path to our door? We'll have to wait and see, but it may be a bit overly optimistic.

    In government, the Department of Energy is still more engaged in nuclear waste cleanup than in energy research. This may change, but the Bush Administration’s financial largess has not yet extended to significant additional funding for energy research. As noted in my last column, the administration's brief flirtation with killing the President's Quality Award may still be the definitive statement on their support to quality. The jury may still be out on this one. ASQ, as a professional society, is struggling with the whole concept of quality as a profession in today’s business climate. ASQ membership Numbers continue to drop. We begin to ask, “What's wrong with quality?”

    The answer may be “Nothing.” We just have to learn how to repackage quality, whether in business or government.

    In the environmental arena, Executive Order 13148, requiring environmental management systems at applicable government facilities, appears to have jump-started new awareness and activities. EMS implementation in the private sector continues to grow, perhaps not as fast as ISO 9001, but it grows nonetheless. ISO 14001 and ISO 14004 are undergoing their first revision cycle, and new interest in them may be emerging in the U.S. and globally. The Bush Administration appears to have sputtered a few times on environment, with unpopular positions on the Kyoto Protocols, oil drilling in the Alaskan wilderness, and motor vehicle mileage ratings to reduce emissions and conserve fuel consumption, etc.; but the administration has not backed off from Executive Order 13148 and has agreed to reduce arsenic levels in drinking water. Recently, EPA announced that it would proceed with controversial dredging in the Hudson River in New York to remove polychlorinated biphenals (PCBs), a carcinogenic compound used in electrical transformers, from the river sludge. Again, the jury is still out.

    Right now, government continues to wallow in uncertainty and indecision for quality, energy, and the environment. Business continues its slowdown, and the "energy boom of the new millennium" has not occurred yet. For EED, government and business are our barometers. The best that we can do is to watch carefully what transpires over the next 12–24 months. Stay tuned.

    If you are interested in the state of quality in higher education, here is an update from the trenches.

    The good news is that the North Central Association of Colleges and Schools, with support from ASQ, is making progress with its Academic Quality Improvement Project (AQIP). AQIP is designed to enable schools that are accredited by the North Central Association to replace their current cycle of re-accreditation (based on huge audits) with a process of continuous quality improvement. An AQIP team reformulated Baldrige's seven criteria into nine criteria that are a better fit for the higher education setting. Schools can attend a planning conference, use the AQIP nine criteria for self-assessment, and then develop an action plan for improving their processes and performance. With this process in place, a college or university can obtain re-accreditation without conducting a costly on-site visit that dwells on counting books in the library.

    More good news: the Accreditation Board for Engineering and Technology (ABET) is moving ahead with its re-accreditation process based on the Baldrige criteria. The College of Engineering at the University of Alabama has been preparing its self-assessment, based on the ABET criteria. Engineering schools are leading the universities by taking significant steps toward defining and assessing outcomes.

    Still more good news: the Southeastern Universities and Colleges Coalition for Engineering Education (SUCCEED) reports significant progress in reforming engineering education on its member campuses. Check out the excellent article, “Quality Approach Supports Engineering Education Reform” in the July 2001 issue of Quality Progress.

    The small group of quality leaders from U.S. colleges and universities gathered in New York City at the end of July for a conference. There were presentations from Penn State, Rutgers, University of Wisconsin- Madison, Alabama, Cal State, UC-Berkeley, Cornell, and Purdue. The latest major university to launch a quality initiative (this year) is University of Nevada-Las Vegas. Numerous community colleges and four-year colleges in the North Central Association are also launching quality initiatives as part of AQIP.

    There is an increasing interest in quality among universities in other nations. The education track at the Annual Quality Congress attracted university administrators from Brazil, Peru, Puerto Rico, and Uruguay.

    Other good news: we are continuing to make slow progress on developing comparative data. The criteria used for the US News & World Report college rankings are asinine.

    The Pew Charitable Trusts has funded an effort to develop a greatly improved set of criteria that will eventually shake things up considerably. Also, you probably don't realize that up until this year, schools could not receive a report that provided the Graduate Record Examination scores of their own students and national scores against which to compare. However, the Educational Testing Service has made this data available for the students who took the GRE in 98-99. As this data is forthcoming for subsequent years, schools will have an excellent source for comparative evaluations of a standardized outcome measure.

    What is needed to keep the quality movement growing in higher education?

    • We need corporations to open up some free space in their internal quality management workshops for faculty and administrators to attend.
    • More schools need to adopt the University of Alabama's model for a Quality Advisory Board that brings quality professionals from top companies in to advise senior management ranks.
    • We need companies to increase their interest in recruiting students who graduate from schools with active quality improvement initiatives.
    • Internally, we need to keep working on developing outcome measures, stakeholder surveys, and performance indicators.

    In case you are wondering what types of activities are occurring under the quality banner at Alabama, here is a sample of the current projects involving the Office for Continuous Quality Improvement:

    • Process flow charting and redesign of the admissions process.
    • Focus group with students to identify campus health issues.
    • Preparation for focus group session in Birmingham with major employers to identify strengths and weaknesses of the university's career placement process.
    • Focus group with faculty concerning problems associated with delivery of distance education classes.
    • Work with the Student Government Association to assess results from a spring student opinion survey.
    • Planning for a survey of community colleges regarding the process of transferring students to the university.
    • Strategic planning for the Alabama Museum of Natural History.
    • Facilitation for School of Social Work's community development project in rural Alabama counties.
    • Follow up on process redesign for registering distance education students to ensure they can access library cards, parking tags, and computer services.
    • Organizing a brown bag luncheon series for academic department chairs to discuss campus issues.

    That's a good sample of how quality is working in higher education.

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