| Philip Sutton Director, Policy and Strategy Green Innovations Inc. Tel & fax: +61 3 9486 4799 Philip.Sutton@green-innovations.asn.au |
22 April 1999 Version 1.d.w:iii |
Paper marked up in HTML format |
Sheldon, C. (ed.) (1997) ISO 14001 and beyond: Environmental management in the real world. Greenleaf Publishing: Sheffield UK
Copies can be obtained from Greenleaf: greenleaf@worldscope.co.uk
Philip Sutton is the Director of Policy and Strategy of Green Innovations Inc., a not-for-profit think tank and consultancy organisation. He developed the Flora and Fauna Guarantee legislation for the Australian State of Victoria, and now works on the implementation of environmental management systems for sustainability-promoting organisations.
Has your firm adopted an ISO 14001 conforming corporate environmental management system (EMS) to help minimise its own environmental impact? Or is it using the EMS to help it contribute to society´s achievement of ecological sustainability?
If your answer is "yes" to the former and "no" to the latter then you are missing most of the social and commercial value of ISO 14001.
ISO 14001 is a major step forward for environmental management in many countries. However, a 'default' approach to EMSs has arisen because the first firms to introduce EMSs had major direct environmental impacts, often caused by pollution, and were subject to tough regulatory requirements, high materials costs, and critical public scrutiny. This 'default' approach however is not suitable for firms that want to contribute most effectively to the achievement of sustainability.
Alternative approaches are possible and this paper develops the framework for a sustainability-promoting interpretation of ISO 14401. If this framework for applying ISO 14401 is adopted widely it will dramatically improve the chances of achieving sustainability.
This paper is written for those who want to know how their firms could become sustainability-promoting or those who need to know what drives sustainability-promoting firms and how they can use ISO 14001. For example, it is written for:
Over the last hundred years three changes have given rise to a major increase in environmental impacts around the globe. There has been a consistent long term trend for (a) resource intensive goods to get cheaper, (b) for populations to grow and (c) for the scale of economic activity per head in the rich countries to rise. The use of resources has therefore risen dramatically. This in turn has generally translated into greater levels of environmental impact with a consequent need for stronger environmental laws, first at the local level, and then progressively for higher and higher jurisdictions, culminating in international law.
It is now widely recognised that the historic trend of rising environmental damage and resource use is unsustainable and must be reversed.
So there is much talk about the need for communities, governments and firms to pursue sustainable development. While it is generally agreed that sustainable development is a good thing, there is a lot of uncertainty about what it means and what its implications are.
Sustainable development is development that brings about ecological, social and economic sustainability while contributing to the achievement of society´s other goals.
Ecological sustainability involves both:
The rest of this paper will largely focus on ecological sustainability.
Sustainability is a system characteristic. An ecosystem, human community or an economy together with the associated environment can be ecologically sustainable whereas a stand alone product, material, technology or factory cannot. A firm might be economically sustainable (ie. last indefinitely) but it cannot be ecologically sustainable by itself since it is connected to the environment.
Given the global interconnections of ecological systems, societies and economies, it is not possible to have local sustainability without global sustainability.
Since it is only societies with their environment that can be judged to be ecologically sustainable, an EMS can only be judged to be consciously contributing to ecological sustainability if it is focused on effectively helping society to become sustainable rather than just helping the firm to reduce its own environment impact.
A gradual but intensifying process of ´greening´ has been under way in many markets around the world for the last few decades. This evolution has been punctuated by two major surges of growth in environmental concern. The first was in the late 1960s - early ´ 70s and the second occurred in the late 1980s - early ´ 90s.
The first surge alerted the community to the extent of bad environmental practice throughout industry and the community. The second surge, triggered by a deepened realisation of the global dimensions of environmental decline, alerted people to the need for sustainable development. But it will take a third surge to push societies over the threshold so that they make sustainable development as defined above actually happen (2).
What might trigger such a third surge? The next decisive surge is likely to occur as:
Transformative technologies have the power to dramatically
change the environmental impact of industry. But even more
importantly, by altering the industrial structure, they will change
the relative influence of different industry sectors and they will
change public perceptions about what is possible. For example, Amory
Lovins and co-workers at the Rocky Mountain Institute have been
promoting an new car design, based on a hybrid electric drive and a
carbon fibre shell, that could reduce energy use by 75-90% for the
same performance level as current cars. They have attracted about 25
significant companies to invest around US $1000m in this development
and expect to see the new cars rolling out of factories by about the
year 2000.
This technology will have very serious implications for the oil and
steel industries whose products will be virtually displaced in the
automobile market (Lovins et al., 1996).
Another transformative technology that is expected to come on stream
by about the year 2000 is grid-connected solar photovoltaic
electricity generation that will be price competitive with coal-based
electricity. This technology, pioneered by Pacific Solar in
Australia, will fundamentally shake up the coal and electricity
generation industries(3).
Community lifestyle programs: Already programs like
the Global Action Plan are spreading through Europe, North America and
beyond. They involve householders in reviewing their environmental
impact and their consumption patterns. Once an educational feedback
loop back to business is added to these programs they will become a
very powerful influence on ´green´ product development and uptake.
Win-win macro-economic policies: There will not be much
corporate enthusiasm for the pursuit of ecological sustainability
while most businesses think the economy will suffer as a result. But
there is increasing awareness that win-win economic strategies can be
developed to deliver superior environmental, employment and GDP
results (4). The European Union is leading this
development, but interest is being generated elsewhere in the
world.
Green business tools for sustainability: Businesses will not
be able to become proactive in their pursuit of sustainability until
tools are readily available to help them manage themselves as
sustainability-promoting firms. A number of organisations are
developing just such tools (5).
Key corporations go for sustainability: With the globalisation
of the economy, large multinational corporations have become the
dominant players in business. Until a number of these firms break
away from the pack to pursue ecological sustainability as a serious
source of competitive advantage, the bulk of firms will not see
sustainability as having more than public relations significance. A
small but influential band of large multinationals are now moving
tentatively in the direction of such a transformation (6).
Media interest: It is rare for major shifts in public,
corporate or government thinking to occur until the issues are picked
up by the media. The globalisation of the media has gone so far that
local media outlets usually only treat an issue as newsworthy after
the international news networks have picked it up in what they see as
the trend-setting countries.
To achieve ecological sustainability, society will most probably have to do the following:
Improvement at this rate is technically feasible but the implied rate
of social and technical change is extremely testing. Certainly this
magnitude and pace of change will not be achieved if significant
forces in society are opposed to the changes, causing the reform
process to become deadlocked.
So the rate and scale of change needed cannot be achieved without
the support of strategic sections of industry. But, if this support
is to be worth having, it has to be won without compromising the
commitment to the achievement of ecological sustainability.
To achieve ecological sustainability an increasing number of firms,
large and small, will have to take on an internal commitment to help
catalyse the change. These firms need to become
´sustainability-promoting´. The most effective way to do
this is to adopt a sustainability-promoting environmental management
system. However this is easier said than done.
Almost all EMS activity at present falls into a very predictable 'default' pattern which unfortunately is particularly
unsuited to the pursuit of sustainability because of its restricted
focus, as is explained below.
Before describing the 'default' approach a
number of concepts used in the following discussion need to be
explained. In this paper a distinction is made between three
contrasting pairs of terms:
Environment management systems were
first developed to help firms that:
Firms were often motivated to act because of concerns about legal
compliance, risk management and cost saving, all issues that had a
very direct bearing on the welfare of the firm (11).
The 'default' approach, by focussing on
direct, negative environmental impacts, caused firms to
concentrate on their own production processes first. Some firms´
EMSs eventually led them to manage the indirect, negative
impacts of their products on a life-cycle basis (product
stewardship). Only rarely did the EMSs lead to the introduction of
new classes of products to help customers contribute to the
´greening´ of society.
The 'default' approach to EMSs made sense for the heavy
industry sectors, especially while firms were actively bringing their
performance up to a high environmental standard. But the 'default' approach is not very relevant to a significant
majority of business whose indirect impacts are greater than their
direct impacts (12). This helps explain why the
majority of firms is taking a long time become interested in
adopting an environmental management system. Firms with low direct
impacts are either unaware that they could or should be managing
their indirect impacts or they feel that conventional EMS
approaches do not provide an appropriate framework for them.
Unfortunately, what made sense for certain industries for a
certain period of time is now being generalised by many
environmental practitioners as the way to implement an EMS in
all industry in all circumstances. Indeed many practitioners find it
hard to imagine how ISO 14001 could be implemented in a
non-'default' way.
But there are major limitations to the 'default' approach.
These are summarised in Figure 1.
Ecological sustainability and the role of firms
What are the consequences of objectives such as these? Let´s take the example of CO2
reductions. Let´s assume that we will accommodate expected
levels of population increase and economic growth and avoid the
widespread adoption of nuclear power. Under these circumstances it
would be possible to achieve a 60% reduction in CO2 from the 1988
levels if the global efficiency of resources use was improved by
about 5% per annum (8).A typology of environmental
action
The 'default' implementation of EMSs
and its limitations
These firms were particularly
concentrated in sectors such as chemicals, heavy manufacturing and
mining. Their EMSs were introduced to facilitate major improvements
in past bad practice. The key issues covered were pollution, waste
minimisation and energy conservation. These were the environmental
issues that were most easily kept in front of operations managers on
a routine basis (10).
| If EMS is driven ONLY by: | Then: | So: |
| Legal compliance | Firms will only be sensitive to those issues that are the subject of strong, well-enforced laws | Issues such as biodiversity, soil, and heritage conservation and urban planning will be missed. |
| Issues caused directly by the firm | Indirectly caused impacts will be missed (eg. biodiversity loss, poor land use planning) | Firms will not contribute actively to whole system solutions. |
| Negative impacts | Firms will not try to provide solutions to problems caused by others | Opportunities for developing new products or new areas of business will be missed. Opportunities to significantly advance societys capacity to be ecologically sustainable will be lost. |
| Issues that generate politically significant stakeholder reactions | Issues will be ignored until politically significant stakeholder reactions build up | A lot of avoidable damage will be done before action is taken.Problems that are not immediate or acute in their impact on humans or that affect a small percentage of any given population are likely to be ignored. |
| Significant materials costs | Firms will not take action if money cannot be saved and they are also unlikely to take action if materials costs are a small percentage of total costs | Large sections of industry will fail to conserve resources (even when doing so is cost effective). |
| Legal compliance, risk reduction and cost saving | Firms will not explore all opportunities for competitive advantage (eg. non-price or opportunity rather than constraint-based advantages) | Opportunities for improving the quality of products environmentally or for developing new products or new areas of business will be missed. |
| Short-sighted self interest | Firms will not exhibit corporate responsibility or enlightened self-interest and thus they will not tune in to the customers needs as a whole in the context of their family (for people) or strategic alliance network (for firms), the local and global community and the wider environment | Opportunities for a positive relationship between the firm on the one hand, and its customers and the community on the other, will be lost. Opportunities for product improvement or new product development based on a wider perspective of customer need will not be identified |
Far from the 'default' approach being the only way to
frame an EMS, it merely represents one of four possible focuses for
action (see Figure 2.):
Opening up possibilities beyond the 'default'
Also, it draws upon only one of two major sets of motivations:
These wider possibilities can be grouped into two EMS models or paradigms:
|   | Product-and-organisation improvement program |
Sustainability-empowerment program |
| Direct environmental impact | Focus on production process improvement |
(Not applicable) |
| Indirect environmental impact |
Focus product life-cycle performance improvement |
Focus on:
- as means of improving societys environmental performance |
The 'default' model starts with production process improvement and might eventually progress to new product development if the incentives and opportunities are strong enough. The preferred model, explores opportunities first in the area of new product development and the use of the firm´s influence and then progresses through product stewardship to process improvement (see Figure 3).
|   |
The default model or |
The preferred model or |
| Main motivation | Primarily private interest (the firms and the direct customers) |
Both societys need and |
| Main drivers | Pursuit of private opportunity within social constraints set by laws and economic incentives |
Pursuit of social needs and |
| Typical action sequence | Production process improvement >> product stewardship >> new product development |
New product development >> product stewardship >> production process improvement |
New product development is needed to achieve win-win results for the environment and for economic performance. Incremental improvements in products will not achieve sufficiently large and rapid improvements in environmental performance, nor will they achieve this while maintaining the community´s standard of living. The transformative technologies discussed earlier show what is needed and what is often possible when sufficient creativity is applied to the task.
Under a preferred sustainability-promoting model, EMSs should not only help firms to ´do things right´ (ie. minimise the environmental impact existing processes or products) but more importantly they should ensure that firm are ´doing the right thing´ (ie. producing appropriate products and exercising influence in an appropriate fashion).
So firms should design their EMSs to help them to simultaneously create maximum environmental value for society (ie. ecological sustainability) and gain maximum competitive and strategic benefit for themselves. Their EMSs should help them develop green markets and position themselves so that they are ideally suited to satisfy these markets.
Developing ´green´ markets involves more than marketing and product development. Firms will also need to be active in encouraging governments to create appropriate incentive structures to help bring forth such markets.
Although ISO 14001 does not require an EMS to be framed in the 'default'-style, the specification standard and the 14004 implementation guidelines are written in a way that powerfully, if unintentionally, reinforces the 'default' rather than a sustainability-promoting approach.
Unless there is something in the ISO 14001 or 14004 procedures that can be relied upon to lead firms ´out-of-the-box´ and to a sustainability-promoting orientation, their original preoccupations (with pollution, compliance, risk and liability reduction, cost saving, and reducing the firm´s direct impacts rather than helping to achieve sustainability for society) will create a lasting culture that defines and limits what environmental management means for them.
ISO 14001 builds in four mechanisms that some might argue have the potential, over time, to draw a firm across to a sustainability-promoting orientation. These are:
The ISO 14001 requirement to comply with relevant legislation and regulations means that if society legislates to control new issues or manage existing issues differently in order to achieve ecological sustainability, firms will have to respond. However if firms are not internally committed to promoting sustainability they are just as likely to lobby to prevent the legislative change, while maintaining an ISO 14001 conforming EMS.
ISO 14001 requires firms to institute a program for continual improvement in their environmental management systems in line with their own environmental policy. So long as firms commit themselves to legal compliance and pollution prevention and as long as their certifiers think that their EMS policy is appropriate to the nature, scale and environmental impact of their activities, products or services, they are not obliged to take on a sustainability-promoting approach (14). So a firm that was committed to the 'default' approach would simply have to get better at that approach to remain ISO conforming.
ISO 14001 requires firms to determine their issues-scope and environmental directions in their environmental policy. The views of interested parties are only required to be considered when the already-determined-policy is translated into objectives and targets. So, for example, an oil company that committed itself in its policy to reducing the environmental impact of oil production, could ignore arguments from interested parties that the firm should shift from fossil fuel-based oil to renewable energy production when the objectives and targets of the EMS are set.
Given the lack of effective drivers for the adoption of a sustainability-promoting approach in the ISO 14001 process, a firm wanting to avoid the reflex adoption of the 'default' will have to take its own deliberate and self-motivated steps to ensure that it moves in a different direction. Simply following the ISO 14001 requirements and the ISO 14004 guidelines will not be enough to turn things around.
Firms are unlikely to commit themselves to the alternative EMS model if they
think it is pie-in-the-sky.
Practical experience shows just how hard it is to make relatively
small changes in products or production processes. So how can the
vast and seemingly impossible changes needed for ecological
sustainability be achieved. And how can the complexity of the task be
managed?
Goal-directed innovation can be used to achieve win-win solutions in, what appear to
be, impossibly demanding situations. A good illustration of this is
the Japanese pursuit of ´zero defects´ in manufacturing after
the Second World War.
To compete with the Americans, the Japanese needed to lift product
quality while maintaining their cost advantage.
To reduce their defect rate American firms´ inspected their
output. If a higher quality of shipped product was needed the
Americans simply increased the proportion of output inspected,
allowing them to weed out a higher proportion of defective units. But
in the process the cost per item despatched was significantly
increased.
To overtake the Americans the Japanese decided to adopt a much faster
and cheaper improvement process.
The Japanese set ´zero defects´ as their goal even though it
was technically and economically impossible to achieve at that
time.
Innovation programs were set in motion, inspired by the goal. Rather
than taking current best practice as their benchmark, the Japanese
used an ideal goal and then ´reverse engineered´ a solution
that approached the ideal ever more closely. Instead of controlling
quality using inspection, they concentrated on manufacturing
improvements to make it highly probable that the product was produced
correctly the first time. This quality improvement process
decreased costs and gave the Japanese a decisive competitive
advantage.
But if an effective innovation program is implemented, new methods or
solutions can lower the static cost curve for each time period (see
Figure 5), causing costs to plummet over time (see Figure 6).
Stretch goals are used to inspire both a steady stream of incremental
improvements and leapfrog or breakthrough innovations.
Inspirational ´green´ stretch goals
Du Pont, which has a 190 year history of pursuing a ´zero
accidents´ policy, now has an accident rate less than one
thirtieth of the average for all US industry and one tenth of the
average for comparable industries globally. With this experience
under its belt the company is now extending its approach to the
environment. In 1994 it established company goals of ´zero waste
and emissions´ (Du Pont, 1994). Many other companies have
similar inspirational goals.
So highly demanding inspirational goals are already a reality in
business. But for a sustainability-promoting firm it is necessary to
reformulate the stretch goals. This is because the inspirational
goals have to drive the firm´s sustainability-empowerment program
and not just its product-and-organisation improvement program.
Consequently the goals need to focus on what must be done to help
society to become ecologically sustainable.
Appropriate inspirational stretch goals for a sustainability-promoting firm would be to foster the
creation of an economy and society that aims to achieve:
Others have also discovered the magic of whole-system design, that
is, the potential for win-win solutions. It underpins, for example,
the power of TQM techniques, business process reengineering, Eli
Goldratt´s Theory of Constraints, cleaner production,
eco-redesign and life-cycle assessment.
When societies, economies and technologies become complex, most people
focus on incremental improvements in the parts of the system. This
leaves a vast reservoir of economic and environmental efficiency gains
to be made by those who can handle complexity.
If firms are to improve their chances of tapping this reservoir, they
must give their EMSs the widest possible scope. For example it
should cover (a) the development of new technologies, competencies
and products, (b) the use of influence to change the rules of the
game and to mobilise alliances of firms, (c) the lifecycle
improvement of products and (d) the upgrading of production processes
(see Figure 8).
Whole system design is not just a very good source of productivity
gains, it is also the only way that ecological sustainability can be
achieved - because, as stated earlier sustainability is system
characteristic and cannot be achieved by focussing on
uncoordinated changes in parts of the system. This is why the 'default' application of ISO 14001, which emphasises
introspective improvements in the firm´s own product and
organisational performance, cannot result in society becoming
ecologically sustainable.
Knowing that whole system design is the key
to achieving ecological sustainability with win-win productivity gains
is one thing. Doing something about it is another.
There are two reasons why whole system design is not undertaken often.
One is that most people have not been trained to handle this
approach. The other is simply that it is harder to do whole system
design and implement whole system changes than it is to deal with
incremental changes. That is why those looking for fast pay-off
action tend to leave the area alone.
One very important way to reduce the difficulty of handling whole
systems is to use techniques that reduce the complexity of change.
One reason that incremental change is easier than system change is
that most of the factors affecting the process are fixed or
predetermined. But once a change to the wider system is proposed
things become much more uncertain because, while there is one present
there can be many possible futures.
This uncertainty can be reduced however by creating shared visions
around which individual actions can coalesce. Commercial early mover
risk can be reduced even further if shared visions are adopted as
standardised system frameworks and are formalised as industry
standards.
Standardised system frameworks can also be used to maintain the
sustainability of the system over time. A number of standardised
system frameworks could be designed which, when combined, are known
to be sustainable. Then, as long as each product is designed to fit
into one of these frameworks, the sustainability of the system as a
whole is likely to be maintained.
For example all products could be required to be recycled through a
limited number of standard take-back and reprocessing systems (eg.
kerb-side mixed paper collection, parcel-post-style return system for
high value-low bulk products). A product would only be allowed onto
particular regional markets if it could be handled by the available
systems or if the product manager was prepared to develop and
implement a viable alternative return-recycling system, that is, they
take responsibility for creating a new standardised system
framework.
An analogous approach is now being used in software development, the
construction of very large office towers, sophisticated aircraft, and
to the coordination of inter-related product offerings from a range
of independent companies. In these areas systems are reaching such
high levels of complexity that no one person can comprehend all the
detail of the system.
To make it possible for many people to work together on these
products or projects, it is necessary to treat the components of the
products or indeed whole products as modules of a larger system. A
shared standard is developed, or adopted defacto. Then the
components or products can be designed and fabricated
semi-independently and yet they still work together finally.
It might be appropriate for standardised system frameworks to be
developed by joint government-industry-community working groups.
National and international standardisation bodies might play a role
too.
Standardised system frameworks should be considered in the EMS process
before the EMS objectives and targets are set. The need to fit into
existing standardised system frameworks would be determined in the
review stage of the EMS. Then, in the EMS strategy process, the need
for new frameworks would be considered. Applicable standardised
system frameworks would guide the setting of objectives and
targets.
How can all these ideas be brought together to create an interpretation of
ISO 14001 that promotes sustainability-promoting?
An EMS that conforms to ISO 14001 is a mechanism for ensuring that a
firm:
Practical idealism
Zero defects? Impossible!
The economics and management theory of inspirational stretch
goals
In the short term it is almost always true that
the further a goal is pursued, the higher the unit costs will be (see
Figure 4 for a typical static cost curve).
These inspiration stretch goals will be more easily acted on if a vision of
what they mean can be developed and shared widely. For example a
closed-cycle economy (see Figure 7) could be pictured as one where
materials are cascaded down through applications that can use
recycled materials of ever lower quality. This is then followed by
regenerative recycling of these materials to restore their quality
ready for another cycle of cascade use (17).
The magic of whole-system design
Over the last couple of decades, the Rocky Mountain Institute has
shown that large energy savings can often be achieved more
cheaply than small ones in buildings, motors and many other
technical systems through the use of whole-system redesign (Lovins et
al., 1996).
Managing complexity: standardised
system frameworks
An EMS structure for a ´non-default´
sustainability-promoting interpretation of ISO 14001
For a sustainability-promoting firm, it is desirable to group these steps
into a four stage cycle (see Figure 9), starting with a review and
the setting of directions. See Figure 10 for an examination of the
differences between a by-the-book application of ISO 14001 and a
possible sustainability-promoting interpretation.
By-the-book application of ISO 14001/4 |
Sustainability-promoting interpretation of ISO 14001/4 (SPI) |
Comments |
| 0 - Initial environmental review | 1 - Review and set directions | Initial review not required by BTB if EMS already operating |
|   | Values review | BTB equivalent is under Environmental policy |
| Review of views of interested parties | Review of societys environmental needs and societys environmental strategies | Systematic assessment of environmental needs not specifically required by BTB |
| Identification of environmental aspects | Review of significant -ve environmental impacts and aspects for the product-and-organisation improvement program | If initial review not required, BTB equivalent is under planning |
| Legislative and regulatory requirements (14001) and voluntary requirements (14004) | Requirements review (legal, voluntary, etc.) | If initial review not required, BTB equivalent is under planning |
| Examination of all existing environmental management practices and procedures; evaluation of feedback from the investigation of previous incidents | Management review | If initial review not required, BTB equivalent is under management review |
| 1 - Environmental policy | Policy development |   |
|   | Strategy development | Not required by BTB |
|   | Identification of significant environmental aspects for the sustainability-empowerment program | Not specifically required by BTB |
| 2 - Planning | 2 - Plan |   |
| Environmental aspects |   | The SPI equivalent is under review and set directions |
| Legal and other requirements |   | The SPI equivalent is under review and set directions |
| Objectives and targets | Objectives and targets |   |
| Environmental management programs | Environmental management programs |   |
| 3 - Implementation and operation | 3 - Do |   |
| Structure and responsibility; training, awareness and competence; EMS documentation; document control; operational control; emergency preparedness and response | Same as BTB |   |
| 4 - Checking and corrective action | 4 - Check and correct |   |
| Monitoring and measurement; non-conformance and corrective and preventive action; records; EMS audits. | Same as BTB |   |
| 5 - Management review |   | The SPI equivalent is under review and set directions |
Underpinning the EMS cycle for a sustainability-promoting interpretation of ISO 14001 is top level and organisation-wide commitment to the values that drive the firm´s environmental action and commitment to capability building, real action outcomes and continual improvement. The issue of ´commitment´ and the ´review and set directions´ and ´plan´ steps are discussed in detail below.
Every step in a sustainability-promoting EMS cycle needs to be underpinned by a
commitment to values, capability, outcomes and continual improvement.
The key values underpinning a sustainability-promoting approach are:
The adoption of these values represents a growth in environmental
maturity along the spectrum from compliance with externally imposed
constraints, to keeping ahead of society´s constraints, to
proactively pursuing the achievement of society´s goals as a
commercial strategy.
Capability:
A sustainability-promoting firm will need skills not required by other firms.
They will need skills in:
The ´review and set
directions´ stage of a sustainability-promoting EMS cycle
integrates the ISO 14001-14004 steps of:
The review
There are five suggested elements of the review part of the ´review
and set directions´ process.
A values review: a firm will not be fully aware of the
objectives behind the EMS review process, its choice of EMS scope, the
classes of environmental issues to be managed and the roles that the
firm wants to play unless it clarifies its values at the start of the
process.
An assessment of environmental needs: a
sustainability-promoting firm should not rely wholly on interested
parties and stakeholders to draw its attention to society´s
environmental needs. The firm should take responsibility for
proactively identifying these needs as part of its normal customer
needs assessment process. In this case the focus is on the
5-in-1 Customer.
The identification of significant negative environmental impacts
and the environmental aspects for the product-and-organisation
improvement program: this corresponds to the 'default' consideration of impacts and environmental aspects. Unlike in the
by-the-book ISO process, this step should be taken routinely ahead of
the policy step so that the results inform policy development. An
assessment should also be made of the relative impact of direct
versus indirect (life-cycle) impacts.
A review of requirements (legal or voluntary): This is the
same as the by-the-book ISO implementation. This review should also
routinely feed into policy development.
A management review of the defacto or formal EMS: ISO 14001
requires an environmental management system review at the end of each
formal EMS cycle and prior to the policy-making step at the start of
the next cycle. However, firms implementing an EMS for the first
time are not required to assess their defacto EMS in the initial
review phase that precedes policy making. Failure to carry out this
assessment, however, could lead to weaknesses in the EMS policy and
hence in the first formal EMS.
Setting directions
There are three suggested elements of the direction setting part
of the ´review and set directions´ process.
The development of policy: The EMS policy (´environmental
policy´ in ISO by-the-book jargon) for a sustainability-promoting
firm must much more rigorously set the framework for setting
objectives and targets than is the case for a 'default'-style
firm. So the policy may need to be longer than the typical
inspirational one pager. If the EMS policy has to be longer or
complex than is appropriate for inspirational and educational
purposes, then a separate inspirational summary policy should be
produced.
The EMS policy can refer to externally developed sets of guiding
principles. A sustainability-promoting firm might wish to refer to
the Guiding Principles.
Strategy development:
reactive firms do not need strategies, proactive ones do. A
sustainability-promoting firm must therefore include a strategy step
in their EMS cycle. The strategy should be guided by the EMS policy
or at least a good draft of it. Then some of the key insights or
directions that emerge from the strategy development process may need
to be included in the final EMS policy.
The objective of the strategy is to help the firm decide how it
can best help society achieve ecological sustainability while at the
same time advancing its own competitive or strategic interests. The
strategy will need to guide the firm on the best combination of
action:
Overall, sustainability-empowerment programs (product or
influence-based) benefit society more than product-and-organisation
improvement programs, despite the very considerable importance of the
latter. Fortunately in many cases firms will also gain the greatest
long term commercial advantage from pursuing an empowering program of
product development.
The identification of significant environmental aspects for the
sustainability-empowerment program: It has always been possible
under ISO 14001 to look at the environmental aspects associated with
an empowering program. But the structure of the typical or 'default' ISO EMS cycle makes it very difficult to identify
them. Environmental aspects for the product-and-organisation
improvement program are relatively easy. For example, when a firm
works out what it is doing to cause pollution it has identified the
relevant improvement aspect. To find a sustainability-empowerment
aspect, a firm would have to decide which action, out of the infinite
possibilities, it should take to help society achieve ecological
sustainability. A strategy is needed to decide on the best choice of
activity. Only then can the firm work out the
sustainability-empowerment aspects of its operations that need to be
managed well to implement its choice.
The ´plan´ stage of a sustainability-promoting firm´s EMS
cycle needs to be different from the ISO by-the-book cycle. It is
desirable to start the ´plan´ stage of a
sustainability-promoting EMS cycle with the setting of objectives
and verifiable targets that cover three program
areas:
After setting objectives and targets, a sustainability-promoting
firm develops practical how-to programs for
sustainability-empowerment, product-and-organisation improvement and
EMS quality assurance. These implementation programs can contain fast
track actions and actions with longer term pay-offs.
Sustainability-promoting firms can exhibit a number
of different orientations towards environmental issues. The three
stances of most interest to a sustainability-promoting firm
are:
Many firms that eventually adopt an ethical opportunist stance, may
start out as ´cynical opportunists´ (20).
For example, successful experience with ´green´ niche
marketing or with the application of an EMS may create a positive
climate in which the shift can occur.
The catalyst stance is reflected in the cultural or policy
influence the organisation attempts to achieve in order to promote
sustainability. Advertising, customer and employee education
programs, sponsorships and policy advocacy are some of the channels
for achieving influence. They are often used at present to promote
the self-interest of firms rather than the public good. However this
need not be the case if firms are actively repositioning themselves
to make a living by pursuing the public good. This stance is
relevant for all organisations but sometimes it might be the only one
that can be pursued actively if it is not possible, at a particular
point in time, to make rapid progress developing or improving
products or production processes.
The pioneering stance is likely to be most successful where
complete management units are involved. This allows all the
management structures and processes to be aligned with the stance.
Such an alignment is necessary if the organisation is to have the
sticking power to make the necessary breakthroughs. Pioneering
management units can exist within an organisation that is
opportunistic overall.
The catalyst stance would almost always be found in combination ie.
with ethical opportunism or pioneering. Because of the risk and cost
associated with pioneering, it would be rare for an organisation to
pioneer in everything it did, even where pioneering is a core
strategy.
The following guiding principles could be referred to in the EMS policy of a sustainability-promoting
organisation.
If firms want to be classed as 'sustainability-promoting' there are five things they need to do as their minimum commitment:
For many firms, the last
three decades years have been a confusing time. No sooner have
governments set environmental standards than the community has
demanded higher standards. It seems that trade-offs between
environmental quality and economic production are not respected and
the goal-posts keep shifting.
However, once firms adopt a sustainability orientation this constant
change is no longer seen as a lack of faith but as continual
improvement leading to a win-win environmental and economic outcome,
that is, to sustainable development.
Firms will improve their chances of long term success if they
understand the destination and can position themselves to take
advantage of the change. So when firms design their environmental
management system it is essential that they adopt a
sustainability-promoting interpretation of ISO 14001. Anything less
than this is not best practice.
I would like to thank Manningham City Council in Melbourne, Australia
for their vision and pioneering spirit in pursuing
sustainability-orientated environmental management. No words can
express the debt that I owe Kathy Preece for her continuing
support.
2 Sustainable development is often wrongly
defined as development that takes environment into account in a
´balanced´ way, that is, environmental objectives are not
pursued too vigorously so as to reduce the perceived risk of a major
trade-off with economic, employment and income objectives.
3 Pacific Solar is owned by the largest
electricity generator in Australia. See Lawley, 1996.
4 See DRI, 1994 and Jacobs, 1994.
5 For example,
European Partners for the Environment/SustainAbility/Wuppertal
Institute in Europe, the Natural Step Environmental Institute in
Sweden, Australia and the US and Green Innovations Inc. in Australia
are developing sustainability orientated management tools for
business.
6 Given the slowness with which even the
leading countries are putting an ecological sustainability compatible
industrial base, leading-edge ´green´ firms may have to
support the establishment from scratch of such an industrial base in
one or more of the newly developing countries. Historically major
shifts in industrial paradigm are associated with a geographical shift
in the technological frontier or leading edge (the frontier moved from
craft production in the UK to production based on interchangeable
parts/mass production in the US, and from there to Japan with the
development of lean production). See Wallace 1996.
7 The predicament that gives rise to the need
for such massive changes is well described in Meadows et al. 1992.
This study also make it clear that the restructuring of the economy
needs to begin urgently.
8 If solar electricity rapidly displaces coal
generation and is used to produce hydrogen as an oil and gas
substitute then the 5% per annum improvement in resource use
efficiency could be lowered while still achieving the necessary
greenhouse gas reduction targets.
9 A firm can
exert influence via advertising, public relations, training, strategic
alliances, lobbying, etc.
10 For most heavy industries, issues such as
flora and fauna, soil conservation, and urban planning tend to
attract attention as direct environmental impacts only
occasionally, for example when capital works are undertaken and after
that they are forgotten again. (Mining is an exception with flora
and fauna protection being a continuing issue.) Even where
organisations try to manage their indirect impacts, most
life-cycle assessment techniques do not deal with issues such as
flora and fauna, soil conservation, and urban planning because they
are hard to reduce to a small number of simple, quantifiable
indices.
11 Issues that caused difficulty mainly for
society or the natural environment, rather than for the firm, were
much less likely to be dealt with.
12 Even in a resource intensive economy
like Australia´s, the sectors of the economy that include firms
with high direct impact (ie. mining, agriculture, forestry,
fishing, energy production, manufacturing, construction, transport and
tourism) only constitute about 40% of the total economy. Since not
all firms in these high impact sectors themselves have high
direct impact, the 'default' approach to EMSs would not
apply well to more than 60% of the Australian economy. (Figures based
on data from ABS 1996.)
13 Being driven by society´s interests
means much more than being ´market-led´. Many firms undertake
extensive market research to find out what the public´s needs or
desired are. However, this research usually only discovers aggregated
private needs and interests. Even where public opinion polling
deliberately searches for people´s views on what is good for the
community-as-a-whole asking for off-the-cuff comments is not good
enough because of the complexity of the issues involved. The results
of in-depth consultations and research studies would need to be drawn
on as well.
14 It is unlikely that certifiers will see
the promotion of ecological sustainability as the logical end point
of ISO 14001 continual improvement programs.
15 The Wuppertal Institute
in Germany has adopted this goal and is promoting it in industry
through its Factor 10 Club.
16 Where virtually all the throughput
resources (those not recycled in the economy) are derived from
renewable sources (eg. solar energy and biological materials).
17 The
regenerative recycling of non-toxic biodegradable material is
possible now using natural processes (eg. composting and digestion to
decompose biodegradeable materials and vegetation growth as a way of
building the breakdown products back into useful complex materials).
However, a comprehensive system for the regenerative recycling of
toxic and non-biodegradable materials is still to be developed.
18 ISO 14001
requires compliance with relevant legislation and regulations. This
sets the standard´s only environmental performance requirements.
19 Eli Goldratt is actively disseminating
methods for achieving ´no major trade-off´ outcomes in
industry. See The Avraham Y. Goldratt Institute, 1994 and Goldratt,
1994
20 A cynical opportunist organisation
is interested in environmental issues only as a source of commercial
opportunities and for no other reason. Cynical opportunist firms add
´green´ products to the range as market research shows that
there is demand. However, products with poor environmental
performance are continued without improvement for as long as demand
exists. Cynical opportunist companies are more likely to perform well
in the ´green´ market if their product development and
production staff servicing ´green´ niches personally have
ethical opportunist or pioneer orientations. A team made up entirely
of cynics will find it hard to identify ´green´ opportunities
and is unlikely to have the commitment or insights necessary to make
´green´ initiatives work well.
Only the ethical opportunist, catalyst and pioneer stances match the
spirit of ISO 14000. However, the ISO 14000 series definition of
continual improvement (improvement up to the level set in the EMS
policy) and the ability to apply ISO 14001 to only parts of an
organisation suggests that a cynical opportunist organisation could
successfully meet the technical requirements of the standard and be
certified if it wrote its policy carefully.
21 'Sustainability take-off' is as a condition where concern for the
sustainability is embedded in the culture, where action to achieve sustainability is continuous over
decades, where sustainability programs do not get significantly wound back during economic down-
turns (or better still they are advanced in ways that are appropriate to that stage of the business cycle),
where changes in government do not significantly set back sustainability-promotion, where public
policy is driven by a vision of a preferred sustainable future and where the leading sections of the
business community are sustainability-promoting. A discussion of the related concept of ecological
take-off can be found at: http://www.peg.apc.org/~psutton/takeoff2.htm
22 The author calls this the 5-in-1 Customer concept where the firms
tries to simultaneously serve the needs of five 'customer' classes: the immediate user of the product, as
well as the local community, people globally, future generations and nature.
23 Pioneering involves developing new capacities or qualities from
scratch. Leapfrogging involves significant advances that go beyond incremental change.
ABS, Catalogue No.
52.06: National income, expenditure and product for the June quarter
1996. (Canberra: Australian Bureau of Statistics, 1996).
DRI et al., Potential benefits of integration of
environmental and economic policies: an incentive-based approach to
policy integration, report prepared for the European Commission
(London: Graham and Trotman, 1994).
Du Pont, Safety, health and environment 1994 progress
report. (Wilmington, Delaware: Du Pont, 1994).
Goldratt E., It´s not luck. (Aldershot, Hampshire:
Gower, 1994).
Houghton J., G. Jenkins and J. Ephramus (Eds.), Climate
change: the IPCC scientific assessment. (New York: Cambridge
University Press, 1990).
Houghton, J., B. Filho, B. Callander, N. Harris, A. Kattenberg and
K. Maskell (Eds.), Climate Change 1995: The science of climate
change (New York: Cambridge University Press, 1995).
Jacobs, M., Green jobs? The employment implications of
environmental policy (Brussels: World Wide Fund for Nature,
1994).
Lawley, P., "Photovoltaics - a quantum jump", presented
at 3rd Renewable Energy Technologies and Remote Area Power Supplies
Conference (Cairns, Australia, 1996).
Lovins, A., M. Brylawski, D. Cramer, and T. Moore,
Hypercars: materials, manufacturing and policy implications
(Snowmass, Colorado: Rocky Mountain Institute, 1996).
Meadows, D., D. Meadows and J. Randers, Beyond the
limits: global collapse or a sustainable future. (London:
Earthscan, 1992).
The Avraham Y Goldratt Institute, An introduction to The Avraham Y Goldratt Institute
and the Theory of Constraints. (New Haven: The Avraham Y Goldratt
Institute, 1994).
Wallace, D, Sustainable industrialisation. (London:
Earthscan, 1996).
Commitment
Review and set directions
ISO 14001 establishes the environmental
policy as the key driver of the whole EMS. It is therefore vital the
policy document is highly strategic and avoids the inadvertent
commitment of the organisation to the 'default' EMS approach.
The policy can only do this if an effective review processes starts
every turn of the EMS cycle.
For each area of action, the
firm will need to use the strategy process to decide on the
appropriate degree of urgency, magnitude of change and timeframe.
Given society´s need for leapfrog change and the firm´s need
for products to be commercially viable at each point in time, it might
be appropriate for firms to work on the development of more than one
generation of product improvements or new products at any one time.Plan
Instead of undertaking the identification of
environmental aspects for the product-and-organisation improvement
program and the legal and other requirements at the
´planning´ stage, as is done in the by-the-book application
of ISO 14001, these activities are best carried out for all
sustainability-promoting firms in the ´review and set
directions´ stage.
Strategic stances
The ethical
opportunist firm encourages a general improvement in the
environmental performance of all its products and all its processes.
Ethical opportunist firms need to have well developed search skills
for finding the best available methods and product ideas and they need
to be adept at taking on new methods and technologies.Guiding principles for a sustainability-promoting
organisation
There are six additional actions that it would be desirable for sustainability-promoting firms to take to
magnify their effectiveness. They should:
ensure that when products (including services) and production
processes are developed or modified to meet the needs of the active users that they are also designed to
serve the needs of the local community, people globally, future generations and nature
(22)Conclusion
Acknowledgments
Notes
References
Last modified: 22 April 1999