- Why should I undertake an environmental management system for my organization?
- What conditions should be in place for my organization to successfully implement an EMS?
- What does it cost to adopt an EMS, and how long does it take?
- How does registering my EMS to the ISO 14001 international EMS standard add value?
- Why is MPCA rewarding ISO 14001 EMSs and not other types?
- Can a company with an EMS – even one registered to ISO 14001 – still be out of compliance with regulatory requirements?
A. According to the most widely-accepted international standard (ISO 14001), an EMS is a continual cycle of planning, implementing, reviewing and improving the actions an organization takes to meet its environmental obligations. Organizations that undertake an EMS can experience improvements in:
- access to markets;
- supply chain relationships;
- product time to market;
- efficiency & profitability;
- worker health & safety;
- environmental performance;
- compliance (and cost of compliance);
- regulatory relationships;
- stockholder & public image;
- insurance cost or access;
- access to capital.
A. MPCA has been observing the world of environmental management systems since 1996. We’ve assessed the prospects for leveraging EMSs through experiments in permitting, compliance, auditing and enforcement, and we’ve observed pilot programs in other states as well.
Based on that experience, EMSs seem to work best when a culture of commitment to environmental performance and compliance already exists in an organization. Such an organization has already committed people and dollars to assessing facility inputs and outputs (including pollutants), and maintaining and tracking compliance. When these conditions are in place, the organization finds that expanding the scope of their environmental management and formalizing its documentation is not that great (or costly) a leap. In return, the facility’s EMS (and auditing) provides a channel of accountability to customers, community, and investors, allowing the facility to demonstrate its commitment using commonly-accepted and transparent standards.
In contrast, facilities which have no history of environmental commitment and in fact may have problems with basic compliance with pollutant limits or recordkeeping requirements should not look to an EMS as the solution to their problems. First, the facility’s management must state policy, commit resources, implement internal control systems, and establish a meaningful track record (2-5 years) of improved management. By definition, these are essential components of an EMS so this commitment will mean that the EMS can accompany or follow the improvement.
A. EMSs may address the full range of an organization’s impacts on the environment and neighboring community. Those impacts may include:
- noise, traffic, visual, odor;
- water, fuel (type), electricity use;
- soil & groundwater contamination;
- raw material use;
- upstream suppliers, either their effect on your overall product or the effect of your specifications on them;
- downstream processing;
- product life cycle;
- facility property;
- on-site or vicinity natural resources management;
- air emissions;
- water discharges;
- hazardous & solid waste;
- off-specification product;
- accidents & process upsets;
The scope of an organization’s EMS may be narrow, addressing only a few of the impacts above, or it can be all-encompassing, requiring considerable internal resources to document, evaluate, start up, measure, and continually improve. For an ambitious EMS, even the smallest organization should plan on a year elapsed time, 1,000 hours of personnel time, and about 2 hours of basic training per employee to start up their EMS and have it ready for external auditing. Hiring a consultant for assistance in setting up your EMS can free up your valuable staff resources, but the cost of a consultant will start at about $10,000 for smaller, less-complex facilities and go up from there.
Of course, you should never hire a consultant with the expectation of being handed a “black box” EMS. This defeats the purpose of integration into overall facility management and developing the capacity for internal process control and oversight.
Retaining a third party to audit the EMS can cost from about $2,000 to $20,000, depending on the size and complexity of your organization. MPCA recommends third-party EMS auditing. Registration to the ISO 14001 standard (in other words, the certificate) can cost another $4,000 to $10,000 per year, but is a relatively small fixed cost compared to the cost of employee time to maintain your commitment to an overall system.
The long-term quantifiable financial returns on this investment can often far exceed the initial cost. The short-term payback on the initial investment of $30,000 to $150,000 (for most facilities except the largest) is usually a matter of 1-2 years, depending on how much your organization has already invested in environmental compliance and performance improvement. This payback period can be much shorter in cases where customer and/or market demands are part of the decision for getting certified.
A. ISO 14001 is the most widely accepted international standard (over 8,000 U.S. users and over 130,000 worldwide), and has become the framework for industry-specific EMS standards commonly in use in the U.S. (e.g., RC 14001 for chemical manufacturers) and sometimes required of suppliers by original equipment manufacturers such as the auto industry.
An EMS following a different international framework, or designed by an internal or industry framework will under the right conditions be useful in improving and formalizing environmental management. It will not, however, offer as much access to markets or customers as does ISO 14001.
Using, and at some point, registering to the ISO 14001 standard elevates an internally-oriented EMS to external transparency and accountability. Since its inception in 1996, the ISO 14001 system has developed and improved international, national, company, and auditor accountability and oversight. Because of the predictability of this system, customers, agencies, and community stakeholders are most likely to accept an audited ISO 14001 EMS as evidence of high-performance environmental management. This acceptance translates into improved competitiveness and profitability, regulatory flexibility, recognition, and goodwill – both tangible and intangible values.
A. The MPCA offers a flexible air permit option for ISO-conforming EMS users. While MPCA considered accommodating EMSs outside of the ISO standard, it was deemed infeasible since MPCA would have to take on additional and expensive new roles relating to EMS standard development, auditing, and auditor qualification and oversight. In addition, it has became evident that many companies were adopting EMSs based on the ISO standard, and were even having their EMSs audited based on ISO and supporting requirements, without necessarily taking the final step of ISO registration. Basing rewards on the ISO 14001 standard therefore seemed the best balance of state and user needs.
A. Yes, but it is MPCA’s position that such a situation cannot continue for long or because of the same root causes.
The MPCA recognizes that because the regulatory system does not always produce continual compliance, we frequently must work with or pursue enforcement with companies to correct noncompliance. Our goal therefore is to have EMSs self-discover, report, and quickly deal with noncompliance, particularly significant noncompliance. “Noncompliance” includes incidents of adverse or unpermitted environmental impacts, failure to maintain adequate and timely records, or failure to submit accurate and timely reports as required by statute, rule or permit.
Our message to auditors, registrars, and facilities seeking conformance to the ISO 14001 EMS standard is that instances of related/repeated noncompliance after corrective EMS action should lead to major nonconformance determinations, which should in turn lead to loss of ISO registration should noncompliance related to the root cause continue.
Leaders in the ISO 14001 EMS auditing community have interpreted ISO and ANSI-ASQ National Accreditation Board (ANAB, formerly the Registrar Accreditation Board) guidance and advisories to support MPCA’s position.
The MPCA continues to work with companies, auditors, and registrars to set a high Minnesota standard for linking ISO registration and conformance to environmental compliance.