Do Environmental Management Systems Improve Performance?
by Susan L.K. Briggs
There is an ongoing debate about the value environmental management systems (EMSs) provide to organizations. The debate arises from a lack of comparable, quantifiable data demonstrating companies with a formal EMS produce less environmental emissions, discharges and waste than companies without one.
A number of programs, however, have published results showing improvements in environmental performance by companies with an EMS.
But there are differing opinions on what constitutes “improved performance.” A parochial view is focused on quantitative reductions in pollutant emissions and discharges, waste generation, natural resource use or other negative environmental impacts. Improvements, however, also can be measured in terms of:
- Management system improvement—qualitative and quantitative improvements to management support processessuch as employee training and awareness, compliance assurance processes or corrective/preventive action programs.
- Organization reputation—unquantifiable improvements in an organization’s reputation or improved relations with regulatory bodies, community organizations or other interested parties.
- Financial benefits—quantitative cost savings or cost avoidance associated with any of the improvements.
A summary description of recent initiatives to quantify improvements resulting from EMS implementation follows.
Remas is a recently completed European study on the benefits of an EMS within the context of regulation.1 The study was led by the Environ-ment Agency for England and Wales. Its aim was to identify elements of an EMS that are key to driving performance.
An environmental management assessment tool was developed and administered to about 300 participating organizations, some with robust EMSs and others with no formal systems.
The results show sites registered to ISO 14001 by a national accreditation body scored higher on the Remas assessment. Those registered to the European Eco-Management and Audit Scheme (EMAS) scored even higher.
The study reports a more robust EMS, in particular EMAS, improved site environmental management. This, in turn, was linked to better environmental and regulatory performance.
Available data on water and air emissions from participating organizations showed a link between better site environmental management and better environmental performance, although the confidence level varied by region and sector.
The project notes a reasonably strong link between better site environmental management and regulatory performance. But the researchers believe regional differences in the regulatory approach (for example, the mix of permit levels, numbers of inspections and enforcement strategies) influenced this relationship.
In some regions the relationship between environmental management and regulatory performance led to more instances of permit condition breaches and enforcement, while in others it led to fewer permit breaches.
In terms of EMS elements that drive performance improvement, preliminary results indicate an environmental policy and compliance and conformance control appear to lead to better resource (such as raw materials, water and energy) use in processes.
Performance monitoring, environmental reporting, and compliance and conformance control seem to have the most effect in reducing releases to air and water. Further analysis of key drivers is forthcoming.
EPA Performance Tracking
The Environmental Protection Agency (EPA) national performance track program requires member organizations to implement an EMS and report annually on quantitative environmental goals they aim to meet over their three-year membership term.
When selecting goals, members can choose from a range of environmental indicators. But in all cases, these goals must go beyond the applicable compliance limits or requirements.
The recently published fourth annual EPA progress report shows the improvements these companies have realized in one year.2 Overall, 40 member companies achieved a 3,200 ton decrease in air emissions plus a 3,900 metric ton reduction of carbon dioxide equivalent in greenhouse gases when aggregated.
Some 114 companies collectively reduced hazardous waste generation by 791 tons. A 528 million gallon decrease was reported by 108 organizations that committed to reducing water consumption. Companies that made commitments to reuse and recycle material increased use of these reused and recycled materials by 42,000 tons.
In some cases, the results are more compelling when production levels are taken into account and the results are normalized. For example, the 528 million gallons of water previously quoted actually reflects a 4.3 billion gallon reduction when increased production levels are considered.
The member companies avoided the generation of 66,000 metric tons of carbon dioxide equivalent of greenhouse gases. Use of 19 trillion British thermal units (Btu) was avoided by 147 members collectively despite a gross increase of 22 trillion Btu.
Finally, the 791 tons of hazardous waste mentioned earlier actually translates to a 2,230 ton avoidance of hazardous waste generation.
Management System Improvements
Although it is not always captured in quantitative studies, many organizations give anecdotal testimony to management system improvements and benefits achieved after implementing an EMS. These often include the following:
- Development of a robust and rigorous system to identify environmental hazards and implement controls in a prioritized fashion, focusing limited resources in critical areas and reducing the overall risk profile of the organization and unacceptable occupational exposures to employees.
- Establishment of a systematic way to manage environmental requirements and responsibilities to ensure compliance and uninterrupted operations including action in anticipation of new or revised regulatory requirements.
- Improved awareness of environmental issues, enhanced environmental ethic, and increased responsibility and accountability for environmental performance by staff through training, communication and flow-down of goals to relevant levels of the organization. Increases in employee morale and motivation not only result in a “feel good” factor but also enlarge the number of viable suggestions for improvements and potential cost savings.
- Formal documentation of
pro-cesses and procedures to make environmental management
de-pendent on systems rather than
on an individual’s institutional knowledge and to enable transfer and diffusion of important information over time and from one employee to another.
Direct and indirect cost savings often are associated with implementing the following EMS improvements:
- Establishment or enhancement of an active pollution prevention program results in elimination of hazardous materials and associated waste generation. This, in turn, eliminates the applicability of regulatory requirements including costs associated with sample collection and analysis, training, reporting and inspections.
- Reductions in resource consumption, hazardous material inputs and undesirable byproducts result in decreased costs of production, compliance, waste disposal and management costs, thereby increasing funds for mission related endeavors and profits.
- Establishment of a systematic method to manage regulatory requirements allows avoidance of the costs associated with fines, permit denials and legal fees.
- Implementation of preventive measures and plans minimizes the potential for emergency response costs (for example, costs of response, cleanup and possible regulatory penalties, litigation fees and settlements associated with spills or releases).
It is often difficult to categorize a particular effort as solely an environmental management system or financial improvement.
In one case study, an organization focused its efforts on eliminating regulatory requirements by reengineering processes and substituting nonhazardous materials. As an alternative to chemical water treatment to control bacterial fouling and prevent scale formation, ozone magnetic field based water treatment systems were installed on cooling water towers.
These systems eliminated the chemical treatment of cooling water with corrosion inhibitors and biocides. This change not only resulted in $15,000 savings per year but also—more importantly—eliminated a chemically contaminated and regulated waste stream that eventually discharged to an aquifer.
Additionally, switching to this nonhazardous system eliminated the applicability of costly regulatory requirements such as periodic sampling, analysis and reporting. The switch also eliminated a potential source of drinking water contamination for the community.
In another case, a small metal cleaning operation implemented chemical substitution to eliminate the burden of regulatory requirements and waste disposal costs.
Nonhazardous, citric based solvents replaced methanol and acetone, thereby eliminating the hazardous waste disposal costs. The change also eliminated administrative costs associated with regulatory required training for affected workers and maintaining a satellite waste accumulation area.
In preparation for the 10th anniversary of the publication of ISO 14001, International Organization for Stan-dardization technical committee 207 will compile data on the benefits achieved by organizations implementing an ISO 14001 based EMS.
Data on any of the four improvement categories mentioned earlier are sought from organizations of all sizes and sectors across the globe.3 The information will be used to communicate and promote the value of ISO 14001, particularly for small and medium-sized enterprises.
Websites, workshops and publications are planned. The goal is to share best practices and promote ISO 14001. The work is scheduled for completion in early 2007.
In partnership with the ANSI-ASQ National Accreditation Board and QSU Publishing Co., the Wharton Risk Management and Decision Processes Center initiated a research project to determine whether third-party EMSs drive environmental performance improvements.
The proposed research will focus on two issues:
- Identify factors that have the most influence on the decision to pursue ISO 14001 certification.
- Determine the impact of ISO 14001 registration on environmental performance.
Influencing factors might include positive imaging (to underscore correction of past flaws or to position a corporation as a leader in environmental consciousness), customer requirements, system improvements and corporate edict.
Environmental performance impact might be measured in terms of the degree to which organizations have achieved their EMS objectives and targets.
The debate might continue, and studies will go on. But the results to date confirm, at least qualitatively, that organizations implementing an EMS reap benefits.
REFERENCES AND NOTE
- Remas, http://remas.ewindows.eu.org.
- Performance Track Fourth Annual Progress Report, www.epa.gov/performancetrack/downloads/PT_4th_Progress_Report.pdf (case sensitive).
- Contact the U.S. technical advisory group to technical committee 207 at firstname.lastname@example.org if your organization can contribute information on performance improvements.
SUSAN L.K. BRIGGS is director of environment, health and safety for Textron Systems, Wilmington, MA. She holds a bachelor’s degree in natural science from Harvard University. Briggs was a U.S. expert on the ISO technical committee (TC) 207, subcommittee 1, working groups revising ISO 14001 and ISO 14004 and currently chairs subtag 1 of the U.S. technical advisory group to TC 207. She is a member of ASQ and an ASQ certified quality engineer, auditor and manager.