The document discusses lessons learned from implementing ISO 14001 environmental management systems. It notes that while ISO 14001 was initially hyped, many companies took a wait-and-see approach. It was pushed by large automakers requiring suppliers to implement it. The document provides 10 tips for an effective EMS, including designing the system to suit organizational needs, choosing representatives wisely, and not isolating EMS responsibilities but involving various business units. Maintaining an EMS program is the most critical component after initial certification.

1. The Journal for ISO 14001, OHSAS 18001, RC14001 and Environmental Professionals Volume 10, Number 9 October/November 2005
Q:
Now that ISO 14001 has graduated into its first
revision, can you pass along some noteworthy
lessons that we might be able to include in our
environmental management system?
A:
When the original version of ISO 14001 was
rolled out in September 1996, many pundits
were quick to extol the virtues of this sibling of
ISO 9001 and what it could provide a diverse
array of regulated industries.Unfortunately for the ISO stan-
dard, the reality did not immediately match the marketing
hype. Many organizations took a wait and see approach.
If not for the Big Three automakers pushing suppliers
to implement ISO 14001 and in some cases attain ISO
14001 certification, the international environmental man-
agement system standard may have not gotten its much-
needed boost in the early years of life.
Electronics companies, such as IBM, and consumer
giants like Sony,have also played a part in driving ISO 14001
as the new gold standard in environmental management
systems.
Interestingly, certain legislation, such as the European
Union’s Restriction of the Use of Certain Hazardous
Substances in Electrical and Electronic Equipment (RoHS),
its directive on Waste Electrical and Electronic Equipment
(WEEE) and the Sarbanes-Oxley Act in the United States,
may fuel still more interest in an ISO 14001-focused EMS.
Time will tell.
What’s Really Important?
If the years since the initial publication of ISO 14001
have taught us anything it’s that third-party certification to
the standard is only the beginning,and having a solid main-
tenance program to maintain the effectiveness of an EMS
program is the most critical component of any program.
Here’s a brief summary of some of the responses I
received when I queried a number of company managers
regarding their ISO 14001 certifications:
“We passed our inspection. We don’t need any help.”
“We have our certificate. We’re all set.”
“What’s lead auditor training, and who conducts
that?”
“We only generate small stuff. We’re a clean facility.
Why do we need all this stuff?”
Sound familiar?
One case that really sticks out in my mind is a US facil-
ity that achieved certification to ISO 14001,but still received
an enforcement action for violations related to secondary
tank containment.
A survey conducted by ENDS in 2003 raised concerns
over ISO 14001 certification. Interestingly, the survey found
internal motivation to be the single biggest driver, followed
closely by supply chain and competitive pressures. In reali-
ty, some companies view certification as an end in and of
itself. They become complacent until the next audit.
Real Deal
Unfortunately, such an approach can lead to situations
that may compromise the organization. Whether it’s to
maintain ISO 14001 certification, 9001 or even OHSAS
18001 certification for that matter, the real value in being
certified is often missed.
I believe that many of the changes in the latest release
of ISO 14001 were an attempt to close some of the holes in
the earlier edition. That’s why I believe Communications
was revamped, and a new clause, 4.5.2 was spun off from
the original 4.5.1 Monitoring and measurement.
Too many organizations, while developing and main-
taining their EMSs, took ill-advised shortcuts.As in the case
Keep Your Eye on the
System Not the Paper
Ask an Expert
By Gabriele Crognale
(continued)
R E P R I N T October November 2005 ENVIRONMENTAL SYSTEMS UPDATE 1

2. 2 ENVIRONMENTAL SYSTEMS UPDATE October November 2005 R E P R I N T
of any construction project, shortcuts are no substitute for
a quality product, and oversight is mandatory. So what
about an EMS that is to be built with integrity and pride?
What should you look for in developing and eventually
maintaining your EMS?
Here are 10 surefire tips to eliminate some of the
potential obstacles to an effective EMS program:
Tip1 - Design your EMS to suit your needs, not to sat-
isfy outside parties. It’s your system. You will use it day in
and day out. But also make sure that it satisfies all the ele-
ments of ISO 14001. If in doubt and the item makes sense
to you and clarifies some function, leave it in. It will proba-
bly become part of your EMS over time anyway. A good
example of this would be a work instruction for one’s
responsibility, especially if that function may have an
adverse impact when a particular person is out for some
reason. Having a back-up plan is a wise investment.
Tip 2 – Choose EMS representatives wisely. They can
either make or break your system. This person should be
someone whom upper management will listen to even if
their message goes against the organization’s norm.In addi-
tion, he or she should have latitude to disagree with upper
management if the need arises. I know of one organization
that picked internal auditors with an agenda. This is not
only counterproductive,it creates resistance to any potential
gains that may result from the audit.
Tip 3 – Apply the KISS Principle in crafting your pro-
cedures or work instructions. Procedures that include
everything but the kitchen sink may be a bit too much to
handle. Consider linking supplemental information to
make instructions more manageable.
Tip 4 – If you need to outsource some of the work, do
so sooner rather than later.One organization thought it was
getting a bargain from a service provider, but later found
that its experts had limited environmental management
and compliance expertise. More often than not, some com-
panies expend greater energies in the purchase of a copier
than thoroughly researching the credentials of consultants.
Tip 5 – Make sure tailored training is really tailored to
your facility and not just stock training materials with cos-
metic edits.
Tip 6 –Thoroughly research any training providers
you employ. Check their qualifications and the areas of
expertise they claim to possess. Be wary of vendors whose
credentials or web sites, don’t jive with their claims.
Tip 7 – Ensure that your organization takes ownership
of the EMS components, from start to continual improve-
ment. In some organizations, the end to the means is the
internal audit. Corrective actions tend to be immediate and
somewhat localized without looking at big picture issues
that relate to root cause. In such cases, audits and corrective
actions move in a continuous loop with no clear solution.
Instead, take a grassroots approach. If a worker on the floor
believes in the EMS, they will be more willing to support it.
There’s strength in numbers!
Tip 8 – Don’t isolate EMS responsibilities. Involve as
many business units as you can. At one organization, the
EMS team had neglected to include the input of the
research and development technician. That omission came
out during a training exercise and it was discovered that the
company used chemicals that may have been subject to the
Toxic Substances Control Act (TSCA). A simple tool, such
as a block diagram would have identified this chemical use.
Ideally, this would have come earlier in the process had the
right people been involved.
Tip 9 – Go to bat for your team when necessary. In
some instances, management representatives are left to
flounder alone to move the EMS forward. This is not a pru-
dent management approach.
Tip 10 – Start over to see what you may have missed,
or to see what else you can try.
Gabriele Crognale, P.E., is the founder of MCG &
Associates and is affiliated with several non-profit organiza-
tions, which offer his courses and tailored ISO 14001/EMS
implementation, training and auditing services. He has
trained a number of employees of Fortune 50 companies,
including GM and ChevronTexaco. He authored several
books, including, Environmental Management Strategies: The
21st Century Perspective (Prentice-Hall). He may be reached
at mriso14k@yahoo.com. I
Ask an Expert
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