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Volume 8 · Issue 2 · February 2003


ISO 14001/4 CDs Out for Balloting
US TAG Gets Recommendation of "No" on ISO/CD2 14001

The second committee drafts (CD2s) for the revision of ISO 14001:1996 and ISO 14004:1996 have begun to circulate for balloting and comment, but the US vote on the CD2 ballot for ISO 14001 may not be for approval. The US Technical Advisory Group (TAG) to ISO Technical Committee (TC) 207 and all other participating member bodies (P-members) of the TC have until April 7, 2003, to provide their votes and to submit comments on the CDs.

Meanwhile, the US task group (TG) to TC 207’s WG 5 on climate change submitted comments on February 13, 2003, on the working drafts (WDs) of two standards on greenhouse gas (GHG) emissions, with a call for a delay in the next WG 5 meeting to ensure there is adequate time to review the drafts and develop national and international consensus before moving forward.

In a letter to all TAG members dated January 31, 2003, Connie G. Ritzert, Chair of the US Sub-Technical Advisory Group (SubTAG) to Subcommittee (SC) 1, Environmental Management Systems, and lead US delegate to SC 1, provided a February 28 deadline for TAG members to provide votes and comments on each of the two CD2s so that consensus US positions can be developed on each when the TAG meets in Dallas March 10-11, 2003.

Two Different Recommendations
In addition, Ritzert provided the following recommendations to the TAG based on "the input of the other individuals who have been involved in the international deliberations on these 14001 and 14004 revisions over the last few years":

  • A "No" vote on ISO/CD2 14001, with both editorial and technical comments
  • A "YES" vote on ISO/CD2 14004 to move ISO 14004 to the Draft International Standard (DIS) stage, with both editorial and technical comments.

Ritzert had the input of all the US delegates to Work Groups (WGs) 1 and 2 of SC 1, which are responsible for the revisions to ISO 14001 and ISO 14004, respectively: Jim Highlands, SubTAG 1 Vice Chair and WG 1 Expert; Phil Stapleton, WG 2 Convenor and previous WG 2 Expert; Susan Briggs, WG 2 Expert; and Chris Bell, previous WG 1 Expert. "The resulting recommendations are not necessarily our personal positions but reflect our collective experience at the international level and our understanding of US interests based on past SubTAG deliberations," noted Ritzert in the letter accompanying the recommendations, CD2s, ballots and comment templates. "They are intended only to assist you in making your decisions about your votes and comments."

Both CD2s were produced in Cancun in October 2002, although there was a delay in circulating the draft revision of ISO 14001 to permit a survey of SC 1 P-members to ensure there were no significant outstanding concerns that had not been addressed in Cancun (for more information, see "ISO 14004 CD2 for Ballot Ready, ISO 14001 CD2 Awaits Survey", THE OUTLOOK, October 2002).

"The international survey process resulted in support for issuing ISO/CD2 14001, as we expected," confirmed Ritzert in response to a question from THE OUTLOOK. The version of ISO 14001 now circulating is therefore the same one that came out of Cancun and on which the US provided comments in responding to the survey.

The recommendation to disapprove of ISO/CD2 14001 with comments is the result of concerns with the CD2. When drafting of the revisions to ISO 14001:1996 began, there was international agreement that the next edition of ISO 14001 would be drafted to improve the clarity of the requirements and translatability and to increase compatibility with ISO 9001:2000, but not to make changes that result in the addition of new requirements to the environmental management system (EMS) requirements standard.

The agreement was modified somewhat by a resolution adopted by WG 1 in response to a proposal from several P-members, which essentially held that "new" requirements might be added if they were needed for purposes of compatibility with ISO 9001:2000. The US delegation had some success during the addressing of comments on the first CD in reversing some changes that introduced new language and potential new requirements.

However, the recommendation of a vote to disapprove with comments is based on three major concerns with ISO/CD2 14001, which THE OUTLOOK has summarized as follows:

  1. Subclause 4.3.2, Legal and Other Requirements, adds new language that constitutes a new requirement to determine how legal and other requirements apply to an organization’s environmental aspects.
  2. Subclause 4.3.1, Environmental Aspects, contains new language that creates uncertainty about the boundaries of an organization’s environmental aspects and the extent to which certain aspects must be addressed within its EMS.
  3. Subclause 4.5.3, Nonconformity and Preventive and Corrective Action, contains new language to promote the use of preventive action in line with ISO 9001:2000. While US SubTAG 1 supports the emphasis on prevention, there is concern that the specific changes made in the CD2 language will impose confusing or unrealistic requirements.

"By comparison, the recommendation to approve ISO/CD2 14004 has to do with the fact that there have been significant changes to ISO 14004:1996, but they have been generally favorable to the US positions," acknowledged Ritzert in the US SubTAG 1 recommendation.

"In particular, the US has had considerable input on the changes made to Subclause 4.3.1 on Environmental Aspects…and has participated in Editing Groups that have made significant editorial improvements to the document…. Efforts have been made to streamline the document (although more can be done in this area) to ensure internal consistency and to ensure consistency with the changes being considered to ISO 14001."

The SubTAG 1 Chair nevertheless encourages the TAG members to provide comments for further improvement of ISO/CD2 14004. "We believe there are several areas in the standard that can benefit from additional changes, and we encourage TAG members to submit comments so that consensus positions on US recommendations can be reached at the March meeting."

THE OUTLOOK will provide more information on the CD2s of ISO 14001 and ISO 14004 in future coverage and a report on the US SubTAG 1 meeting March 10-11, 2003.

GHG Standards May Take Longer by Moving Too Fast
The US TG that is developing US positions and providing/supporting US delegates to TC 207/WG 5, which was created for the drafting of ISO standards on GHG emissions, submitted 48 pages of comments on the following WD1s:

  • ISO/WD1 14064-1, Principles and Requirements for Measuring, Monitoring and Reporting Entity- and Project-Level Greenhouse Gas Emissions and/or Removals
  • ISO/WD1 14064-2, Principles and Guidelines for Greenhouse Gas Validation, Registration, Verification and Certification.

The two WD1s are the outcome of a meeting of WG 5 in Berlin in November 2002, at which four existing ad hoc groups (AHGs) and a new Editing AHG examined evaluations of existing national, regional and local GHG standards and other documents and sought agreement on the content and an approach to the drafting of an ISO standard(s) by WG 5. At that time, only one document was in existence and was expected to be the basis of WG 5’s output. Subsequent work by the AHGs resulted in development of the two WD1s, which were received by the US TG in early January 2003. Comments were to be submitted to the Secretariat and Convenor of WG 5 by February 13.

Dr. Sergio F. Galeano and Dr. B. Tod Delaney, who are the Co-Chairs of the US TG as well as US delegates to WG 5, sent a request to the Secretariat and Convenor on February 3 that the next meeting of WG 5, scheduled for March 2003, be delayed. The short deadline for turnaround of comments, which also made it impossible for the US TG to meet and develop consensus positions on the WD1s, and some concerns with the content and size of the WD1 documents were factors in the request. Despite the fact that the Secretariat and Convenor could not accept the US request because of the preparations already made for a March meeting, the US TG leadership included in the US comments a formal request for a delay until May 2003.

In the cover letter accompanying the US comments to WG 5, Galeano stated the following in support of the delay:

As we signaled in our electronic communication of February 3, we are concerned that the very compressed schedule we are operating under will actually decrease the likelihood of achieving consensus and the prompt publication of ISO GHG standards. Despite the best efforts of the Convenor to distribute these documents, we had only a few weeks to review, evaluate and comment on [them]. The situation was further complicated by the unanticipated growth in the number and size of the documents, from one document of less than 40 pages to two documents totaling over 80 pages. [ISO/WD1 14064-2] was a completely new document, with new, complex and controversial content. Further, we will have only a very short time to review what we expect to be the voluminous comments from other delegations before the March meeting.

This rapid pace makes it very difficult, if not impossible, to carefully and thoughtfully comment on the documents and, more importantly, to build the national and international consensus necessary to a successful conclusion of this process. Moving too fast and not building consensus through a transparent process as we proceed will likely create major delays if draft standards are voted down at an advanced stage.

Accordingly, the US requests that the meeting scheduled for March be postponed until May to provide all participants more time to review, evaluate and communicate about these documents. We…believe that being slightly more deliberate at this stage will ultimately make meetings more efficient and convenient and speed the process up by making consensus more achievable.

Among the key points reflected in the US comments were the following:

  • The ISO GHG documents need to remain "regime neutral" (i.e., they don’t correspond specifically to one country’s or sector’s regulatory approach to GHG emissions) so that they can be used in the full range of international, regional, national and private GHG schemes
  • ISO/WD1 14064-1 departs significantly from the "seed document" that was the focus of attention in Berlin and from the understandings reached at the Berlin meeting’s conclusion on concepts and formats for the GHG standards
  • The Berlin meeting concluded with the understanding that there would be one standard, not two. That having been said, the comments identified "major deficiencies" in ISO/WD1 14064-2, including that it is:
    • Not regime neutral—it essentially reflects an emissions trading system (ETS) regime used in the United Kingdom
    • Based almost entirely on an assumption that organizations will use external, third-party verification, which is inconsistent with the content and approach of ISO/WD1 14064-1 and agreements reached at prior meetings of WG 5 and its predecessor, the Climate Change Task Force (CCTF)
    • Excessively detailed and prescriptive and imposes an unnecessarily complex and bureaucratic process not suitable for entities
    • Not drafted so that its content is coordinated with that of ISO/WD1 14064-1 (e.g., many terms are defined differently) and contains text on monitoring/measuring that does not belong in the discussion of validation/verification.

It is likely that WG 5 will meet in March 2003 as planned, although it is not yet known whether other countries participating in the development of these ISO GHG standards will submit comments similar to those of the US TG in content or number. THE OUTLOOK will provide coverage of developments within WG 5, as appropriate, whether WG 5 meets in March or the US TG to WG 5 meets in Dallas March 10-11 as part of the meeting of the US TAG to TC 207.

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