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Revitalising green management systems Inside Vision and commitment: ensuring management standards keep on giving Case studies: three companies share their experiences Making the most of audits: choice of auditor can make all the difference Risk-based regulation: staying on the right side of the law APRIL 2013 Beyond the easy gains there are still savings and improvements to be found for long-termers taking a sophisticated, collaborative approach Produced by Sponsored by

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Page 1: Revitalising green management systems...ISO 50001. Gareth Williams, Northern Rail’s energy solutions manager, says the energy standard p roved a useful tool to improve its energy

Revitalising green management systems

Inside Vision and commitment: ensuring management standards keep on giving Case studies: three companies share their experiences Making the most of audits: choice of auditor can make all the difference Risk-based regulation: staying on the right side of the law

APRIL 2013

Beyond the easy gains there are still savings and improvements to be found for long-termers taking a sophisticated, collaborative approach

Produced by

Sponsored by

Page 2: Revitalising green management systems...ISO 50001. Gareth Williams, Northern Rail’s energy solutions manager, says the energy standard p roved a useful tool to improve its energy
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BSI is very proud to sponsor and welcome you to this ENDS special report on green management systems and how to get the best from them.

Being the sister to last November’s report on green certification standards, BSI is again delighted to work with ENDS, as they look further into what BSI believes are key tools for driving sustainability and deliver-ing continual business and organisational improvement.

Twenty one years ago, in the same year as the Earth Summit in Rio, BSI produced the world’s first environmental management standard, what became ISO 14001.

Now as ISO 14001 comes of age, its rel-evance, impact and stature have never been more important, as it provides more than 250,000 organisations with the cornerstone management system for their commitment to sustainable activity. Proof of this can be found in the training and certification num-bers, which continue to grow, across all types of organisations, and all parts of the globe, despite the economic instability and recession of the past few years.

Indeed BSI has a spectrum of clients, from those new to ISO 14001, to a significant number who have been certified with us for 15 years or more.

For organisations with such a long-term commitment, this report addresses how they continue to benefit from their mature environmental management systems.

What the report finds is that once these

Environmental management systems and standards have grown in stature in the 20 years since the ISO 14001 was introduced, says BSI

Green management systems: coming of age

organisations have realised annual benefits from energy efficiency, water usage and waste management, they work to expand the profile of ISO 14001 and sustainability throughout their organisation. By getting staff involved from all areas, and all levels, they tap into ideas for improvement and savings that the environmental manager would not have known about. This adds to staff engagement and commitment, as well as company reputation. Their step after this is to take a strategic view of how to drive even more benefits from sustainability, by influencing their supply chains and custom-ers to implement environmental manage-ment standards.

The report goes on to consider the revi-sion of ISO 14001, due in 2015, and how this will impact organisations, as it broadens the requirements they need to consider, such as wider sustainability issues like climate change and water scarcity. BSI, through the committee led by Martin Baxter, policy director of IEMA, is leading the UK’s input into this revision process.

This work, just over two decades since Rio, maintains BSI’s role at the forefront of best practice in sustainability, as we con-tinue to do what we’ve done for over a cen-tury. That is through our role as the UK’s national standards body, work with busi-ness experts, government bodies, trade associations and consumer groups to cap-ture best practice and structure the knowl-edge all organisations need to succeed.

Sponsored by:

Page 4: Revitalising green management systems...ISO 50001. Gareth Williams, Northern Rail’s energy solutions manager, says the energy standard p roved a useful tool to improve its energy

10 Bowmer & Kirkland: Keeping track of 29 businesses using an integrated management system11 Enhancing value from audits: Choosing the right auditor is the first step 14 Working together on compliance: Setting off on the right foot in the era of risk-based regulation

03 Sponsor’s foreword05 Getting the most out of your ISO 14001 certificate: There are still gains to be found for those in it for the long haul 06 Northern Rail: Energy improvements with ISO 5000106 Camden Transport Services: Helping the council meet its business goals

Contents

Revitalising green management systems

Revitalising green management systemsAn ENDS special report

Author Isabella KaminskiEditor, ENDS Report Alison CarterHead of production Carolyn AverySubeditor Hannah ModuProduction controller Katherine SlavinAdvertising Reena BhariCommercial manager Fawad MinhasPublisher Nick RowcliffePublishing director Donna MurphyCover photograph Perov Stanislav/Alamy

Views expressed are those of the authors and do not necessarily represent those of Environmental Data Services (ENDS) or Haymarket Media Group Ltd

© 2013 Haymarket Media Group LtdAll rights reserved. No part of the publication may be reproduced in material form without the written permission of the copyright owner, except in accordance with the provisions of the Copyright Designs and Patent Act 1988 or under the terms of a licence issued by the Copyright Licensing Agency

ENDSHaymarket Media Group174 Hammersmith RoadLondon W6 7JP, UKT +44 20 8267 8100

ENDS is part of Haymarket Media Group Ltd, registered in England and Wales under company number 1468220. Registered office 174 Hammersmith Road, London W6 7JP, UK

Revitalising green management systems

Inside Vision and commitment: ensuring management standards keep on giving Case studies: three companies share their experiences Making the most of audits: choice of auditor can make all the difference Risk-based regulation: staying on the right side of the law

APRIL 2013

Beyond the easy gains there are still savings and improvements to be found for long-termers taking a sophisticated, collaborative approach

Produced by

Sponsored by

marking service, ENDS produces a range of special reports.

For advertising opportunities contact Reena Bhari at [email protected], tel: +44 20 8267 4634

ENDS (Environmental Data Services) has been a leading source of information on environment, sustainability and carbon for more than 30 years. As well as three subscription services for environmental professionals and a specialist carbon bench-

About ENDS

04

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In November 2012, ENDS looked at how organisations can benefit from certifica-

tion to environmental standards in a spe-cial report Green certified standards. This featured many examples of companies that had made clear cost savings from cutting energy and resource use and by mitigating their environmental risks.

But it also highlighted concerns about ISO 14001, some of which relate to the requirements of the standard itself, set by the International Organization for Standardization.

This follow-on report, Revitalising green management standards, looks at how compa-nies with a mature ISO 14001 certificate can

make the most from the standard as it cur-rently stands. It examines how they can be ahead of the curve in making wider organi-sational changes before a major revision of ISO 14001, which is due to be completed in 2015 (see box, p 9).

Green certified standards also highlighted concerns about the quality of the ISO 14001 certification process. This is important both for organisations seeking certification and for regulators leaning towards a more risk-based approach to compliance.

For companies looking for more than a ‘badge’ on their wall, the next article looks at how to ensure auditing is rigorous and valuable (see p 11). And as regulated

Knowing exactly what you want from certification and a commitment to achieving it are the keys to ongoing gains

Getting the most out of your ISO 14001 certificate

industries are increasingly encouraged to get certified with the incentive of reduced inspections, we look at how regulators are hoping to boost confidence in the certifica-tion process (see pp 14-15).

Low-hanging fruitTo get the most from ISO 14001, organisa-tions need to understand right from the start what they want to get out of it.

There are many external benefits to get-ting certified, such as boosting brand image and improving relationships with regula-tors. Indeed, it often opens up opportunities to enter tendering bids (see Northern Rail case study, p 6).

From the top: senior management backing provides strategic overview and authority to drive change

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But because the cost of certification can be significant, particularly for SMEs, these benefits need to be measured internally. The key to building a good business case is to link environmental improvement explicitly to financial benefits and reduced risks.

Building this business case is relatively straightforward at first. There are several high-profile areas where companies can make quick wins when starting out on the certification journey. These will depend on the sector or industry they are working in, but usually include energy efficiency, water

usage and waste, which can lead to dramatic cost savings.

However, an ISO 14001 certificate is only valid for three years. To retain it, an organi-sation needs to show it has continued to improve its environmental management system.

Andy Green, sustainability sales manager at certification body BM Trada, says finan-cial benefits can be more difficult to quantify further down the line.

“It’s about understanding that they are annual savings. The savings appear on the

bottom line in year one but will still be there in year ten. Having the standard stops you from slipping back into old habits.”

On the simplest level, improvement can mean keeping up to date with technological change. But to make significant improve-ments, changes need be part of a wider stra-tegic approach that links the environment to sound business management and product or service quality.

This could involve examining a product’s life cycle, including its in-use phase and wider impact on the environment. As well

As a train operator, Northern Rail’s energy costs are clearly an important part of its bottom line. In 2010 the company decided to achieve certification to BS 16001, which it later converted to ISO 50001.

Gareth Williams, Northern Rail’s energy solutions manager, says the energy standard proved a useful tool to improve its energy performance on top of ISO 14001, which it had already achieved.

“ISO 14001 is very much an open-ended standard in terms of what you can manage. It’s very easy to do a quick review of your impacts, to monitor your invoices. But it doesn’t have to go much further – we didn’t feel it pushed the boundaries in terms of energy.”

Williams says compatibility between the two standards was crucial. “We don’t want two management systems; we have one integrated system which is certified to both.”

Northern Rail has used ISO 50001 to make significant gains on the ‘non-traction’ side, which includes everything not related to the trains themselves.

Initially there was considerable work to do to build up a strong baseline dataset, particularly in getting site-by-site figures.

“We knew we had to get a better system that could handle invoices for all 463 of our stations. All the invoices had to be manually input into spreadsheets. We had to start challenging invoices that were incorrect or not even ours.”

MonitoringElectricity use in large stations and depots is monitored by half-hourly electricity reports, which are used to balance grid consumption and supply. “We had access to the half-hourly data but no one was using it. The electricity generation industry was geared up to improve data, so we tapped into that

by installing over 300 automatic meter readers.”

The company saved 13% on non-traction energy in 2011, compared with 2009, by cutting its electricity and gas usage by 5,500 megawatt hours. This also saved it more than £500,000.

On the traction side, Williams says fuel data has become more accurate but there are significant engineering problems yet to overcome. “It’s easier to install meters in stations than on a train – the technology is developing but not quite there yet.”

Implementing the standard has, however, led to more driver efficiency training, which looks at using natural gradients and coasting where possible, smooth acceleration and slowing down well before reaching a red light to save fuel. The result has been that, although the company is required by law to use less-efficient low-sulphur fuel, its overall fuel consumption has stayed about the same.

Staff also have on hand a ‘best technology’ guide to use during station refurbishments that outlines which systems, for example which particular lighting, should be installed. “It’s a controlled improvement process. Once this manages itself, we’ll be looking at other areas such as bus replacement services, support fleet vehicles, cycling etc.”

Williams says the standard will help Northern Rail put forward a good case in the next round of rail franchise bidding. “No one can argue with our approach to energy efficiency as we have an internationally recognised standard in energy management.”

Northern Rail: speeding up energy efficiency improvements with ISO 50001

ISO’s energy standard helped the train operator improve fuel efficiency

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as cutting costs, this can lead to new mar-kets and growth opportunities.

Detergent makers Persil and Ariel, for example, have used marketing to communi-cate with customers to save money on wash cycles, which also improves brand loyalty.

Martin Baxter, policy director of the Insti-tute of Environmental Management and Assessment (IEMA), says this is one area being looked at in the ISO 14001 revision. “There’s less emphasis on operational foot-print and more on supply chain and how it’s integrated into the design process for new and modified products.”

Baxter says organisations need to rec-ognise that the economic context within which they operate is constantly chang-ing, which means there is always scope for improvement.

For example, energy efficiency will remain a key area for all organisations, par-ticularly manufacturers, with costs likely to continue rising and pressure to reduce emissions increasing.

ISO 50001Some certifiers recommend the energy-specific management standard ISO 50001 for doing this. Support for this standard is not universal – some think ISO 14001, if used effectively, should be able to manage every aspect of a company’s environmental management – but its proponents believe its targeted approach can lead to bigger savings.

Northern Rail is one example of a com-pany that believes it has benefited from implementing the standard (see box left).

Waste is another area that should not be viewed as a discrete problem. Richard Wat-kins, owner of consultancy Envirosense, says: “With recycling you’re only treating the problem, which you have created. You need to look at your process all the way through to see how you can get more lean.”

He advises his wood and timber company clients to make simple changes, such as ordering the right amount of raw materials in the first place. One way of doing this cost effectively is to make deals with suppliers for non-standard pack sizes. “A lot of it is about simple good business management. If you can cut down the amount of wood you buy, you use less solvent, less energy, create less waste.”

The problem, according to many experts ENDS spoke to, is that certification itself does not necessarily show a real-world improvement in performance because the standard does not specify that outcomes must be measured.

Camden Transport Services, the transport division of London Borough of Camden, manages and maintains a fleet of 250 vehicles and runs passenger services such as school buses.

The council has a large corporate sustainability programme, which covers similar aspects to ISO 14001, so was able to help Camden Transport Services when it decided to pursue certification itself in 2010.

Central expertiseDavid Cohen, quality and performance manager for Camden Transport Services, says the organisation benefitted from the council’s centralised sustainability expertise, particularly in terms of legal compliance.

He says the standard has provided a way of “latching on” to the council’s wider sustainability goals, such as tackling air quality and pollution, waste and carbon management, and enabled it to show good practice.

Before putting the standard in

place, Camden Transport Services had some environmental awareness but its processes were not coordinated effectively. Recycling, for example, was somewhat ad hoc, environmental education within the business was limited and spillages were dealt with as seen fit at the time.

A management system has helped pull all this together in a structured plan with measurable targets and to continually improve operations.

For example, it has streamlined its approach to waste service suppliers to improve service quality and ensure waste gets disposed of properly. As well as saving money, this mitigated the risk of branded waste being dumped in inappropriate places and harming the organisation’s reputation.

Camden Transport Services is due for its first reassessment for the standard this summer. Cohen says the organisation will be re-examining its higher level aims and objectives to see where it stands.

Camden Transport Services: ISO 14001 helps meet council’s goals

Camden Transport Services has a fleet of 250 passenger vehicles

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Green says big improvements cannot be made without genuine commitment within the business. “Where companies are just looking for a certificate on the wall, they see a much smaller return on their investment.”

Ambitious companies need to be proac-tive in identifying where they can get more out of their existing system.

Greg Roberts of manufacturers’ associa-tion EEF says one sign of a stagnant stand-ard is that a single person has continued to be responsible for the company’s entire environmental system. “They’ve been doing it for so long that they should be environ-mental coordinators but are implementing and managing doing it all.”

While an individual can be the focal point for environmental management, the chal-lenge is to get it understood and accepted throughout the organisation.

Roberts recommends getting as many members of staff involved as possible. “Quite often it’s about getting other people involved in identification of where in their area improvements can be made.” This can improve outcomes by discovering untapped areas and gets staff onboard in making any necessary changes.

It can also boost internal morale. Watkins says: “Employees like being part of a com-pany that cares about environmental issues. They like to be identified with a company that’s seen to be doing things correctly and if you get that momentum within a company you can do lots with it.”

Aiming highStaff involvement should extend all the way to the top of the organisation. “They’re the only ones who know how it affects the whole business context,” says Roberts. “And if any changes are needed they’re the ones that can make them happen successfully. If you have done a good job on your environ-mental management system and communi-cated internally then you’re pushing at an open door and they’re already onboard.”

Most experts contacted by ENDS said they did not believe the current standard puts enough emphasis on senior manage-ment buy-in, even though this is seen as crucial to integrating a system fully into the organisation. Several compared it unfavour-ably with European management standard EMAS in this respect.

Some certifying bodies insist on present-ing their audit findings to the organisation’s management team (see box, p 12).

Green says the auditing process should reveal if the organisation has top-level com-mitment. “You can see relatively quickly

from attendance in management meetings if there are a lot of apologies, if resources are not being made available to the environmen-tal manager or team.”

Steve Williams, global deputy technical director of certification body LRQA, says: “Assessors need to be able to speak the lan-guage of the boardroom and the shop floor.”

Strategic changesEngaging senior staff is part of the move towards a more strategic approach.

Experts say that, to be truly effective, envi-ronmental management should not be seen as separate to the organisation’s overall aims. The results of risk assessments, internal audits and external inspections should feed into management reviews and the environ-ment should be part of a company’s wider corporate and social responsibility package.

The ISO 14001 revision is taking account of this strategic approach (see box). Baxter says there has been strong support for this change in emphasis. “We were keen that by trying to make environmental manage-ment more strategic you need to push the environment into other parts of the organi-sation. That’s a new concept because it will make it much more relevant to high-level decision-makers.”

Peter Wilson, partner at ERM, says an environmental system can use the same management methods as other parts of the business, be it marketing or maintenance.

Indeed, companies that have had a certi-fied standard for many years may get partic-ular benefit from stepping back to see how well these areas are integrated.

Melanie Blackmore, managing director of consultancy Blackmores, says many com-panies start out with a quality management system and add environmental and health and safety systems in. “We find that there is quite a lot of duplication. Quite often com-panies have systems which are unwieldy because there are so many additional requirements. You’ve got to look at oppor-tunities for integrating and streamlining them.”

By working on a strategic level, an organi-sation can begin to reap the wider benefits of influencing how it is perceived by its work-

Employees like being... identified with a company that’s seen to be doing

things correctly and if you get that momentum within a company you can do lots with it

The current revision of ISO 14001 is another good reason for organisations to re-examine their environmental management systems.

The revision process, which began in February 2012, incorporates a list of recommendations on the standard made by the International Organization for Standardization (ISO). It also includes a new ‘high-level structure’ – part of a new ISO framework for all management system standards – which will make the environment a more strategic concern within an organisation.

The revision will put more attention on the value chain, support demonstration of legal compliance and ensure the standard is relevant to small and medium businesses.

The BSI technical committee, which developed the first British Standard that evolved into ISO 14001, represents the

expert opinions of UK stakeholders in the revision.

Martin Baxter, policy director of IEMA, who has been appointed as committee chair for the revision by BSI, says support for the changes has been strong so far. “It’s clear there’s an appetite for changing the way in which things are done so there’s more drive from the top.”

Although the revised standard is not due to take effect until 2015, Baxter says organisations should already be asking themselves what the changes will mean and start building them into how they operate.

“It’s not just about having right systems but about having right skills internally. You can evaluate and improve your system now – you don’t have to wait for the standard to do that.”

To comment on the revision visit www.iso.org/14001survey2013

ISO 14001 revision: time to start thinking ahead

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force, investors and local community. “Peo-ple need to determine who the interested parties are and what their needs and expec-tations are,” says Roberts.

One EEF member, which was looking at developing a manufacturing site near residential housing, used its environmen-tal management system to consider how it would communicate with the local commu-nity. From a business point of view, the aim was to speed up and smooth the planning application process, avoiding extra costs and time burdens. “It fits nicely with the stakeholder communication agenda,” says Roberts.

Supply chainThis approach can extend to engaging busi-nesses further down the supply chain.

A growing number of large companies with mature and well-developed manage-ment standards are now putting pressure on their customers and contractors to get certified as well. This is a fruitful area in which to make wider improvements, but it can be a double-edged sword; if a firm is not fully committed to the process it may not be willing to make substantive changes.

Green believes there is a generally low understanding of what is required in a man-agement standard. “This is certainly the case in environmental ones. People see what they consider an obvious problem, such as dealing with hazardous or dangerous mate-rials, but they forget about the mundane things, such as paper or how they transport things and people about.”

Watkins works predominantly with wood and timber firms and says most of his clients are required to implement the standard by the companies they supply. “It’s whether you make ISO 14001 pay for itself and only the company can decide to do that. You shouldn’t sell it on the basis of saving money, but everyone says it does save them a lot.”

Greg Roberts of EEF says the standard needs to be sold well. “Sending them a ques-tionnaire is not enough – it doesn’t engage them. Instead of saying you must have ISO 14001, try to work with them using your expertise. People have got to really want to do it for their business rather than just because their customer says so.”

When this is done well, it can be very effective. Bowmer & Kirkland is one exam-ple of a company that has used pressure from its clients for certification to its advan-tage (see box, left).

Camden Transport Services, on the other hand, has chosen to pursue certification of its own accord (see box, p 7). ■

As a diverse group of 29 companies, mostly construction related, Bowmer & Kirkland had a specific challenge in achieving certification.

David Gregory, quality and environmental manager, says the solution was to build an integrated management system, which brings together a number of standards including ISO 14001. The group has seven ISO 14001 certificates, the first of which was awarded in 2008. Three are attached to the main contracting construction companies that make up the core of its business.

Gregory says its subsidiaries use a set of common processes alongside systems tailored to that particular business. “As a complex organisation it helps stop duplicating effort. A lot of people were coming up with solutions to problems themselves, which was great but was repeated across the group. Now we do that corporately and put in relevant measures into our integrated management system. We end up having something more robust for a lot less effort.”

He says this is particularly true in keeping track of legislative demands; having a structure for staying up to date gives the business confidence that it is fully compliant.

Gregory says the experience of applying ISO 14001 made satisfying its legal requirements under the CRC Energy Efficiency Scheme easier to manage. “If we didn’t have that experience and those skills we would

have approached the legislation quite differently.”

Alongside reducing risk and improving corporate governance, the biggest motivation behind getting the standard was its clients. “We can demonstrate a level of improvement and that’s a huge benefit for our clients.”

Without the standard, the company would be precluded from tendering for a number of major clients, particularly in the public sector.

Staff trainingGregory says the company has avoided making the certificate a badge on the wall by training relevant staff on what certification can offer their business.

“We say you can do this, it’s going to take a lot of time and effort, but for that extra 10% you can get the benefits. They’ve all been quite responsive. You have the output to demonstrate your improvements, which you can sell back to your clients, rather than just the certificate itself.”

Gregory says it is possible to reach a plateau in making improvements in certain areas. “My view is that if you’re reaching a level where you can’t physically do any more – certainly economically – then maintaining that level is equivalent to improvement.”

An important area of continuous focus is the company’s supply chain, as this will vary according to the specific project and individual client requirements.

Bowmer & Kirkland: integrated system helps keeps track

The group of construction-related companies has seven ISO 14001 certificates

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External auditing is a key part of ISO 14001 certification, but concerns have

been raised about the consistency of the process.

This is problematic for regulators becom-ing increasingly reliant on external stand-ards (see pp 14-15) as well as for companies hoping to get the most out of certification.

Richard Watkins, owner of consultancy Envirosense, says the standard provides a basis from which to work, but improve-ment will ultimately depend on either the motivation of the company itself or the qual-ity of its consultant or auditor. “I have seen environmental management standards that really aren’t worth the paper they’re writ-ten on. It’s probably not doing the company much good.”

As a result, organisations looking to get the most out of ISO 14001 are advised to choose their certification body carefully.

Even those with a mature standard should remember they are free to shop around for their next audit.

Most certification bodies are accredited by the UK Accreditation Service (UKAS), which gives a degree of assurance about the quality of certification. But even here there are concerns about consistency, and not all bodies will be appropriate to all companies.

Industry nousThe first step is to find one that knows the company’s industry and its associated regu-lations.

UKAS requires auditors to show a level of sector-specific knowledge. With this in mind, Noel Bell, a former senior policy adviser within the Northern Ireland Envi-ronment Agency’s strategy group, says implementation could be improved by ensuring auditors link this knowledge to

Finding an auditor with industry-specific knowledge is the first step to gaining greater insights from the process

Enhancing value from audits

potential environmental outcomes as they scrutinise a management system.

He noted that soon-to-be-published research by Sniffer will recommend auditors have an independently assessed qualification to show understanding of environmental implications. “This should help with real-world compliance as well, as auditors would know what the actual results of a breach would be.”

Steve Williams, global deputy technical director of certification body LRQA, says its assessors are not only well-versed in the standard’s requirements but also the sector they are working in. “They have an understanding of what is being expected in that sector and can talk to them in their own language.”

LRQA matches assessors to companies by their experience within specific sub-sectors of an industry. “For example, we

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On the shop floor: some auditors like to step away from the desk

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ies have to carefully distinguish between auditing and consultancy. For example, a certifier may mention the possibility for infrared lighting, but would not go into details about how to install it.

If a company does want more input they can choose to go down the consultancy route. While this may be less useful for a company with a mature quality manage-ment system, which is likely to have built up in-house expertise, it can still add a lot to the certification process.

Williams says a company needs to con-sider what it wants from a consultancy: “Will they act as a project manager or will they be expecting the consultant to do every thing for them?”

For those that do decide to go down the consultancy route, it is worth spending time to find one that, like an auditor, is a good fit.

Bespoke solutionGreen says a consultant should create a bespoke solution for that organisation. “It is important to engage one familiar with the relevant industry, who understands the envi-ronmental impacts you’re likely to be facing rather than just someone who understands ISO 14001 and comes with a set of processes that they’ll try and squeeze you into.”

Alternately, a training course for staff may help develop internal skills with the organi-sation that can be used to develop the system more sustainably in the future. ■

Auditing shouldn’t just be hitting people over the head with a stick. You’re

leaving a seed of thought in someone’s headRichard Watkins, Envirosense

Peter Wilson, partner at ERM, says his company has a different approach to auditing than most certification bodies. “UKAS are used to seeing someone sitting in a room methodically working through every part of the standard.

“Most certification bodies spend a lot of time looking at documentation, but the bulk of stuff that happens at a site is not controlled by a written procedure.

“We think certification assessment should be spending a predominant amount of time going about physically, identifying what isn’t right. So we start walking around and explore things.

“For example, we would want to see if there are competent people driving fork-lift trucks. Most certifiers will have a look at training records, but all that really shows is if someone has filled a form in. The only way to find out is to spend time

watching people driving a forklift truck and to speak to them and ask how they do their pre-shift checks.”

Wilson says when an auditor identifies a problem it is seen as a symptom of a wider issue, which may be a management process. “It’s a starting point and then you use it to explore the organisation. You keep digging until you find it.”

ERM’s auditors insist on speaking to senior management as part of the auditing process. “They’ll be confident that they run a really good organisation and if you can make them feel a little bit uncomfortable that will prompt them into action.”

Wilson says this hands-on assessment process is particularly effective in mature standards. “An organisation could do a huge house clean to show there’s nothing physically wrong. However, you can

empty the waste bins but can’t control people’s behaviour. We are still going to be talking to people and asking them to explain things.”

Wilson says this approach also drives compliance. “Somebody’s not been allocated responsibility to make something happen – somebody’s accountable. The underlying reason is not non-compliance, it’s something else. That emphasises the separation between the documentation approach and what happens in reality.”

But he warns about getting bogged down in the nitty gritty of the standard, without remembering what its purpose is. “If something’s gone wrong it doesn’t matter which exact bit of ISO 14001 it falls under – what I want them to understand is in practical terms why it’s happened.”

Auditors getting their hands dirty

have about 4,000 food clients. We wouldn’t put someone experienced in bakery to assess a company in the meat sector.”

Certification body BSI involves a techni-cal expert in the first stage of assessment on all medium and high-risk clients. Their role is to test the client’s system in terms of legal requirements and compliance.

John MacNamara, director of consultancy and training firm Aspects International and an auditor and technical evaluator for certi-fication body Print and Media Certification, says: “To some extent you could audit any sector – some of the principles are the same – but you have no way of knowing if the systems are working or targets have been reached.”

It is this outcome-based approach that many feel the current standard lacks, but despite these perceived failings a committed company and a good auditor can continue to make improvements.

Green points out that, as well as request-ing corrective action if an organisation is not meeting a requirement of the standard, an auditor can make observations which show opportunities for improvement (see p 6).

“People sometimes see auditing as a pass or fail. That’s where having an auditor who is familiar with the industry is really impor-tant, because they will already know what the best methods are,” he says.

Watkins of Envirosense agrees: “Audit-ing shouldn’t just be hitting people over the

head with a stick. You’re leaving a seed of thought in someone’s head.”

Auditor rotationOrganisations should also ask whether they will continue to be assessed by the same auditor over the years or by different people. The general consensus is that rotating audi-tors brings a fresh perspective to the process.

But this view is not universal. BM Trada considers auditor consistency to be impor-tant and tries to avoid rotation, so individu-als get to know the company in depth.

Green says: “Having an auditor that has been with you for several years and under-stands where you have come from can be really helpful.”

However, he adds that some clients spe-cifically request different auditors or ask for different people to audit different aspects of their business.

It is important to note that certifying bod-

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BM TRADA Demonstrate your commitment to the environment

Choosing BM TRADA means you are working with one

scope of UKAS accredited schemes. We pride ourselves on being approachable and responsive, and on helping you maximise the value of your management systems.

ISO 14001 – EnvironmentalISO 50001 – Energy

ISO 9001 – QualityOHSAS 18001 – Health & Safety

Tel: 01494 569700www. .com

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Environmental regulators in the UK have for a long time looked at how they can

reduce inspections and better target their resources. Now, driven by European and national policy, as well as the political lev-erage of government initiatives such as the Red Tape Challenge, the landscape is start-ing to change.

The Environment Agency and the Scot-tish Environment Protection Agency have signalled a clear commitment to a risk-based approach to regulation, while Northern Ire-land is currently drafting its own position.

To get a permit for a regulated activ-ity, companies in England and Wales are required to have an environmental man-agement system in place. Those with a standard certified by an accredited body are given greater recognition. For example, a company with a good Operational Risk Appraisal (OPRA) rating will be inspected less often than one with a poor rating.

Duncan Giddens, senior environment and business adviser for the Environment Agency, says: “The majority of legitimate companies trying to do the right thing should be self-regulating as far as possible.”

He says the agency will not mandate par-ticular standards and organisations are free to develop their own management systems. However, more credit will be given to those based on internationally recognised stand-ards such as ISO 14001 or EMAS. Giddens says not having such a standard puts an additional burden on both the regulator and the company to determine how effective the system is.

But as this approach is likely to reshape the regulatory landscape – in terms of fees and charges as well as the rate of inspections – how can regulators have confidence that a standard means a company has met its legal obligations?

The European REMAS study showed management standards drive environmen-tal improvement, but do not necessarily improve compliance.

There are two potential areas of concern: whether environmental management stand-

ards themselves put enough emphasis on real-world outcomes and whether certifica-tion bodies are doing enough to check legal compliance.

Identifying lawsProponents of ISO 14001 believe it can improve compliance because it requires companies to identify which laws apply to them and to evaluate their compliance status.

Melanie Blackmore, managing director of consultancy Blackmores, says that few organisations do this before getting certi-fied. “There’s an increasing amount of legis-lation and they may have established about a third of what is relevant to them, but not all. That can be a bit of an eye-opener, espe-cially for senior management.”

She says ISO 14001 can be useful in assigning specific people to keep up to date with legislative changes.

Andy Green, sustainability sales manager at certification body BM Trada, says audi-tors commonly see a long list of legislation that may potentially affect the organisation but no real system for ensuring compliance. “It’s much more important for an organisa-

Cooperation between regulators, auditors and companies is becoming increasingly important in the emerging era of risk-based regulation

Working together to improve environmental compliance

tion to understand which legislation applies to the things they’re really doing.”

Others compare ISO 14001 unfavour-ably to the less popular European standard EMAS, saying the latter puts more empha-sis on checking legal compliance. EMAS requires the competent body to check with the environmental regulators on compli-ance status when registering organisations, while ISO 14001 does not.

An extended version of ISO 50001, mean-while, can be used to demonstrate an early action metric under the CRC Energy Effi-ciency Scheme (see p 10).

ImplementationHowever, regulators are much more concerned about how the standards are implemented.

Research body Sniffer recently com-pleted a year-long project on behalf of the UK environment agencies comparing the outcomes of compliance inspections with those of accredited third-party audits of environmental management systems. Its final report, which was due to be published soon after ENDS went to press, will high-light concerns about the alignment between these two processes.

Noel Bell, former senior policy adviser within the Northern Ireland Environ-ment Agency’s strategy group and chair of the Sniffer project’s technical advisory group, says regulators do not have enough confidence in certified standards as they stand, pointing out that once an organisa-tion has achieved a standard it is unlikely to lose it.

“We see vulnerabilities in the process of third-party audits. There are problems around the consistency of certification bod-ies’ approaches and how they audit. We feel that UKAS may need to review its scru-tiny of certification bodies, making it more robust.”

Giddens says certification audits are simply not reliable enough at present. “We think the standards for both the manage-ment system and its assessment are in place,

14The food and drink sector has taken a lead with an industry-specific toolkit

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but are not being used as they should be. In order for certification bodies to do a more consistent and standardised job, UKAS needs to be much more of a regulator.”

He says part of the problem is that some auditors do not put enough emphasis on the end results of environmental management. “They tend to focus on the process, but are not looking at outcomes.”

There are concerns about whether cer-tification bodies are competent to link generic guidance and the specific compli-ance requirements of particular industries. This is where an auditor with experience in a particular sector can be confident in veri-fying the competence of staff at an organi-sation and can identify where real breaches may occur (see pp 11-12).

The food and drink sector is seen as leading the way in this respect, having developed an industry-specific toolkit for environmental management.1

One of the key problem areas identified by Sniffer is the lack of communication between UKAS, certification bodies and regulators.

Its report will recommend that the terms of a memorandum of understanding between the business department (BIS) and UKAS are revised to clarify the level of qual-ity the government expects from third-party accreditation and audits. One suggestion is to set up a steering group to review the memorandum, which could make further recommendations on the standard.

Proactive problem identificationBell says agencies should be more proactive in voicing general problems with particular sectors, for example around waste recovery and management.

He also says there needs to be better communication between agencies and certification bodies about actual cases of non-compliance. Permitted companies already have to advise the regulator about breaches, but high-quality standards can be used to stretch the regulators’ net by extending the principles of regulation to non-permitted sites.

“Certification bodies should be contact-ing regulators to see if there are any prob-lems with a particular company. We would also like certification bodies to be more robust in telling the company to advise the regulator about any breaches.”

Martin Baxter, policy director of IEMA, says a good environmental management system should show that a company is in control of its compliance. “As an organisa-tion you should be committed to comply-ing with the law but recognising that some

things go wrong. Your management system should be picking up when you’re in non-compliance and should be taking action to bring yourself into compliance in the way in which regulators expect and taking a proac-tive approach to doing that.”

Compliance checkPart of the problem is that ISO 14001, and the certification audit process, were not developed to act in lieu of regulatory inspec-tions. The current revision of the standard, due to be completed in 2015, is building in requirements around demonstration of compliance status (see box, p 9).

For its part, UKAS says ISO 14001 covers regulatory compliance in a general sense but the function and focus of regulators and certification bodies is different and conse-quently leads to a difference in approach.

“If the intention is for certification bod-ies to carry out legal compliance audits then this will fundamentally change the relation-ship of the certification body with its cus-tomers. UKAS considers that this would need to be addressed through additional requirements agreed by the certification bodies, UKAS and the regulators.

“UKAS is discussing possible solutions with the regulators but it is ultimately for the regulators themselves to decide what they need and how it should be delivered.”

The Environment Agency is re-exam-ining its own guidance on environmental management systems and permit com-pliance to ensure the focus is on effective implementation rather than just whether a management system is in place.

The agency is also working with several large certifiers and 30 regulated sites in the chemicals, waste, cement and food sectors on a pilot called the Environmental Per-mitting Regulations Assurance Scheme (EPRAS). The intention is to provide a voluntary scheme to give greater earned autonomy and recognition to companies operating well-managed sites.

Certification body BSI, which is part of the pilot, says one of its aims is to use data already being collected and verified by other bodies to help regulators meet their aims.

Certifiers are given extra training on permit compliance-checking as a bolt-on module to an environmental management system audit. It includes, for instance, find-ing out whether the site operator is keep-ing to permitted emissions limits or taking action after near-misses to prevent them becoming permit breaches.

The trials are soon to be completed and the results will be considered by the agency so it can determine whether to go ahead with the scheme. A decision will be made in time to feed into the consultation for annual charges starting in 2014, in preparation for the scheme to go live in April 2015.

Giddens says this timing would allow the scheme to tie into the revision of ISO 14001. However, this does not address the central problem of the reliability of implementa-tion and assessment. “We can come up with better standards but still need to work with operators and certification bodies to ensure that implementation results in bet-ter compliance.”

One way in which the proposed scheme addresses this is by ensuring an organisa-tion’s senior management sign an annual compliance statement. If this is found to have wrong or misleading information, the agency can take action under the environ-mental permitting regulations. Giddens says this places responsibility firmly at a high level within the company.

Bell says this is considered a good model. “It seems to have worked quite well [in other countries] but we are saying even where you haven’t got that formalised part-nership some of the lessons learned should be in the wider application of environmen-tal management systems.”

Regulators are aware they need the sup-port of industry in the move towards a risk-based approach, but it is not yet clear whether the changes will lower costs for individual companies. They could mean lower charges and fewer inspections, but could also lead to longer audits. This is being addressed by the EPRAS trials.

Other suggestions to improve compliance include reporting of positive audits to help well-performing companies stand out from the crowd and to share good practice. ■

DOWNLOAD at endsreport.com/reportsw 1. Food and drink manufacturing industry environmental management toolkit

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Companies may have established about a third of what [legislation] is

relevant to them, but not all. That can be a bit of an eye-opener, especially for senior managementMelanie Blackmore, Blackmores

Page 16: Revitalising green management systems...ISO 50001. Gareth Williams, Northern Rail’s energy solutions manager, says the energy standard p roved a useful tool to improve its energy

It’s not just about having right systems but about having right skills

internally. You can evaluate and improve your system now – you don’t have to wait for the standard to do that

Martin Baxter, IEMA