Developing a New ISO 14001 Reporting Standard
Final guidelines expected to encourage external communication
by Marilyn R. Block
Environmental reporting has been a contentious issue since ISO 14001 was drafted during the mid-1990s. At that time, the work group charged with writing the standard was characterized by two distinct positions.
Some participants wanted to include a requirement that organizations regularly share information about their significant environmental aspects and impacts with interested external parties. Others opposed to a mandatory reporting requirement argued external reporting fell outside the scope of a system that purported to assist in internal management of environmental issues.
Ultimately, compromise language was struck. When published in 1996, ISO 14001, clause 4.4.3, instructed organizations to "consider processes for external communication" on their significant environmental aspects. As written, this clause requires only that an organization decide whether it wishes to establish some form of environmental information sharing. It does not require any communication of significant environmental aspects.
The current ISO 14001 revision effort has provided an opportunity to revisit the issue of voluntary environmental reporting. Proposed language attempts to clarify the original intent by articulating two distinct points. The draft revision first instructs organizations to decide whether to communicate externally about significant environmental aspects. If an organization decides to communicate externally, the standard requires it to establish a process for its external communication.
Creating a standard
In a parallel effort to provide guidance concerning environmental communication without imposing additional auditable requirements on organizations seeking to implement ISO 14001, ISO Technical Committee 207 created environmental communication working group (WG) 4 in 2001. The United States serves as convener of WG 4; Sweden serves as secretary.
According to Amy E. Schaffer, federal regulatory affairs manager, Weyerhaeuser, and former U.S. expert to WG 4, "There was a great deal of interest among developing countries for guidance about communication. Within the United States, interest was expressed by small and medium-sized enterprises that did not know how to begin to communicate."
WG 4's objective is to create a standard that provides guidance on general principles, methods and practices relating to internal and external environmental communication.
The purpose of the standard, says Schaffer, "is to provide guidance for those who are interested in either beginning or enhancing their current environmental communications program."
The first working draft of ISO 14063, Environmental Management--Environmental Communication--Guidelines and Examples, was distributed for comment in October 2001. Comments submitted in response were consolidated into a second working draft (WD 2) distributed at the end of April 2002. The U.S. Technical Advisory Group (TAG) to ISO TC 207 reviewed the second round of comments in preparation for a WG 4 meeting in October 2002.
A third working draft was distributed after the October meeting. Comments submitted to WG 4 in response to this third draft should be available for review by the U.S. TAG in early 2003.
Although the document will continue to evolve, a basic framework has been established that allows ISO 14063 to be used in combination with other standards in the ISO 14000 series or on its own.
To many of the participants who commented on the communication requirement when ISO 14001 was being developed, environmental communication is synonymous with environmental reporting. WG 4 determined it did not want to write a standard limited to environmental reporting. Rather, it wanted to craft a document that reflected a broader array of communication methods and formats.
As Schaffer describes the group's focus, "WD 14063 is intended to provide information on the wide range of communication forms--from formal reports to ongoing dialogue with stakeholders."
A concept integral to this standard is that environmental communication has many purposes and takes many forms. At present, ISO WD 14063 describes environmental communication as a process for both providing information to and obtaining information from internal and external parties.
The body of the document is organized into seven sections. The first three sections are ubiquitous, dealing with scope, normative references, and terms and definitions.
Section 4 presents three principles of environmental communication regardless of the nature of a communication activity: transparency, appropriateness and clarity. Unfortunately, WD 14063 does not offer any explanation for these terms, but WG 4 discussions suggest the following meanings are intended:
Transparency: assumptions relating to environmental messages and information about underlying processes and procedures should be made available to interested parties.
Appropriateness: Selected formats, language and media should present information in a manner suitable for intended audiences.
Clarity: Information should be presented in a manner that allows it to be understood by interested parties.
A practical help box attempts to delineate characteristics of the principles by presenting a series of adjectives associated with interested parties, content of the message and process for conveying the message. Thus, for the principle of "appropriateness," the help box describes interested parties as inclusive and relevant; message content as complete, respectful and timely; and process as continuous, participatory and reliable.
Other descriptors are more puzzling than helpful. For example, appropriate message content is also described as available and durable. It is doubtful readers will understand what WG 4 is trying to convey. I hope this particular section is subject to significant revision.
Section 5 focuses on an environmental communications policy. Current language suggests this is a written policy statement expressing an organization's intentions and principles for communicating environmental information. WD 14063 says the environmental communications policy should be integrated into an organization's overall communications policy if one exists. Moreover, the environmental communications policy should be aligned with an organization's environmental policy.
Incorporating a commitment to environmental communication into an existing environmental policy, particularly for organizations that are ISO 14001 compliant, would appear to be the most direct approach, but the document does not suggest this alternative.
A help box lists more than a dozen issues that should be considered when creating an environmental communications policy. Among them are the public right to know, shareholder expectations and control, market and brand strategies, and feedback mechanisms.
Section 6 discusses environmental communication strategy as a way to implement an environmental communication policy. A series of questions is intended to assist in creating the strategy. Examples are:
Why is the organization engaging in an environmental communication process?
What is the communication timeframe?
Who are the target audiences?
The document falters a bit in this section. Other than encouraging internal and external analyses to generate information that might be used to answer the questions, the only direction offered is to write the organization's strategy. No guidance, example or help box suggests what such a strategy encompasses. Nor is this section successfully separated from the one that follows.
Section on process
The most useful section of the document is likely to be Section 7 on the environmental communication process. It is divided into three subclauses that address planning, performance, and evaluation and improvement. These subclauses are further subdivided to discuss issues such as deciding on the message, choosing appropriate approaches, creating the message and communicating it.
If there is a flaw in the text, it is the effort to present the communications process as linear, with one activity following another in a manner that is not always logical. The current draft discusses establishing environmental communication objectives, then understanding the target audience, deciding on the message and choosing an appropriate approach.
Four subsections later, a discussion about identifying environmental information appears. It would seem identifying environmental information is a prerequisite for deciding on a message and choosing an appropriate approach.
This section also contains help boxes intended to illustrate various points in the text. For example, Section 7 states an organization should understand the target audience. The related help box indicates opinion survey research is a method for obtaining information from a target audience and describes two types of opinion research--focus groups and public opinion surveys--as particularly useful.
In addition to the help boxes, WD 14063 is supported by an annex. The content of the annex has not yet been finalized, although it has been the subject of much discussion. WG 4 has yet to determine whether the annex will contain actual examples of how organizations implement the various steps in a communications effort or bibliographic references that allow users to obtain additional guidance and examples from a diverse array of sources.
When published, ISO 14063 should greatly assist organizations deciding whether to voluntarily provide information to external individuals and groups. Anecdotal data suggest a large number of ISO 14001 registered companies have chosen not to communicate about their significant aspects because they feel ill equipped to do so. ISO 14063 addresses this concern and is likely to encourage increased external environmental communication about the array of environmental issues facing industry today.
MARILYN R. BLOCK is president of MRB Associates, an environmental management system consulting firm in Potomac, MD. She earned a doctorate in human development from the University of Maryland, College Park. Block co-authored the ASQ Quality Press book Integrating ISO 14000 Into a Quality Management System and authored Implementing ISO 14000 and Identifying Environmental Aspects and Impacts. She is a member of ASQ.