This article appeared in Volume III, Number 9, February 1999 issue of "FAILSAFE", the Journal of the Forum for Environmental Law, Science, Engineering and Finance (FELSEF). Posted with permission of the authors on 3/19/99.
__________________________________________________
Wayne Balta
Director
Corporate Environmental Affairs
IBM Corp.
Gayle Woodside
Program Manager
Corporate Environmental Affairs
IBM Corp.
ISO 14001 - the Environmental Management Systems standard - was published in final form in September 1996, and is widely considered to be the most important standard in ISO's environmental management series. The crafters of ISO 14001 were careful to ensure that it is applicable to organizations of varying sizes and circumstances, not just large corporations or those with economic leverage. The intent of the standard is to drive environmental improvements worldwide through a systematic approach to environmental management. However, debates about the value of ISO 14001 and its ability to meet its lofty intentions have been going on since the early 1990s and continue today, even after over two years of experience with implementation and registration to the standard.
Those who developed and published ISO 14001 intended for the requirements of the standard to provide the basis for an effective EMS that fosters environmental awareness and responsibility at all levels, as well as continual improvement of the EMS itself. In essence, implementation of the standard should promote integration of environmental considerations into all levels of the business in a consistent and reliable manner. In addition, as organizations worldwide begin to implement the standard, it was projected by many that overall environmental performance will improve, and as these organizations begin registering to the standard, the registration process will become a means for companies to validate commitment to environmental protection and responsibility. What was not intended by the standard writers was for ISO 14001 to replace governmental legal and regulatory requirements.
Although many proponents of the standard agree that ISO 14001 has met and in some instances has exceeded the intentions of its crafters, others are not so sure. There are those who feel that the monetary investment required for implementation and registration is not offset by tangible benefits. Skeptics think that, overall, ISO 14001 will not improve the world's environmental situation because it does not set environmental performance or technology criteria. Further, they believe organizations that already have an established EMS will see little benefit from aligning their system with the standard. Indeed, they think that there may even be some downside to implementing the standard such as added bureaucracy and requirements for extensive, unneeded documentation.
International Business Machines Corporation (IBM) was involved in the ISO 14001 process from its inception by providing technical expertise to ISO's Technical Committee responsible for drafting this and the other standards within the environmental management series. Thus, we knew the potential benefits (and the potential pitfalls) of the standard from the start. After achieving a worldwide ISO 14001 registration that now includes 26 locations in 12 different countries, IBM emphatically agrees with that proponents of the standard; that is, the implementation and registration process is well worth the expenditure of resources, and benefits derived from the process are tangible and, at least for us, have exceeded expectations - and all at an affordable cost!
IBM's Decision to Seek a Single Worldwide Registration
Because IBM was a part of the ISO 14001 process, our corporate environmental professionals gained firsthand knowledge of what it would take to implement and register to the standard. By mid-1997 many companies, particularly those doing business in Europe and Japan, were registering to the draft standard, and the electronics industry's registration numbers were outpacing other industries by year-end 1997. Five IBM locations, four in Asia Pacific and one in Europe, were registered during this time period. Thus, understanding that benefits of ISO 14001 and not being a company to take a "wait and see" attitude, IBM's top management made its decision in November, 1996, that the company would not only embark upon a journey of implementation and registration to ISO 14001, but also obtain a single worldwide registration covering all worldwide manufacturing and hardware development operations across all business units.
IBM's registration was achieved using a common registrar, Bureau Veritas Quality International (BVQI), which has an international presence and accreditation from numerous country accreditation boards. The decision affected 26 locations as well as the Corporate Environmental Affairs staff, and 115,000 of IBM's 270,000 employees. When the first edition of IBM's single worldwide registration was received on December 10, 1997, just 13 months later and three months ahead of schedule, it was supported by successful ISO 14001 audits of the corporate environmental staff plus 11 of IBM's 26 manufacturing and development (M&D) locations. This first edition of the single worldwide registration was obtained through a sampling process which is accepted by registration accreditation bodies worldwide. All of IBM's M&D locations had proceeded through the registration audit process by year's end 1998. The 26 locations that are part of the worldwide registration have employee populations ranging from 1,000 to 18,000 and are located in all regions of the world, including 5 in Asia Pacific, 2 in Latin America, 8 in Europe, and 11 in Canada and the United States. In 1999 we plan to add two more M&D locations - one in Ireland and one in Thailand.
Why did IBM pursue registration to ISO 14001 in this unique manner? Actually, the decision was quite straightforward. The company has a corporate-wide environmental affairs policy, and its programs, requirements and management system have for many years been applicable no matter where in the world IBM does business. The company has a solid reporting and audit program, equally applicable worldwide, and its feedback process ensures site and country participation in the company's efforts toward continual improvement. Given this, IBM was in an excellent position to pursue a single ISO 14001 registration for its M&D operations. This single worldwide registration - rather than 26 individual registrations - represents a much more effective and efficient business process. It promotes worldwide consistency because it absolutely requires that IBM execute the same global EMS everywhere. The single worldwide registration also distinguishes us in the marketplace; and, it is consistent with IBM's quest for environmental leadership.
Implementation Process
Once IBM made the decision to pursue a single worldwide registration to ISO 14001, we began our implementation process. In truth, implementation was a less daunting task for IBM than some companies may experience, since we have had a strong, centralized EMS in place for over 25 years. The IBM EMS is essentially a two-tiered system, with Corporate and the M&D locations each having the distinct roles. Corporate defines the worldwide EMS requirements, sets worldwide objectives and targets, measures environmental performance, and communicates progress. M&D locations develop and implement programs to conform to IBM's EMS, establish procedures for operational control, report compliance to legal / regulatory bodies and Corporate, and monitor and measure key characteristics. Working within IBM's existing EMS structure, our implementation process included three distinctive steps.
The first step IBM took in its ISO 14001 implementation process was to conduct a global gap analysis. Locations worldwide were asked a series of questions about what they had in place to meet the requirements of ISO 14001. This gap analysis revealed that most IBM locations already had the "basics" of the elements required by ISO 14001 in place, although some areas of the system could be enhanced. Areas for potential enhancements included employee awareness of the environmental policy, document control, complete EMS audits (previous audits focused on legal / regulatory and IBM environmental requirements), and a more formalized process for identifying environmental aspects and impacts.
As a second step, IBM developed and published a Worldwide EMS Manual applicable to activities, products, and services which formally aligned IBM's existing environmental management processes with ISO 14001. The Worldwide EMS Manual defined the company's single environmental policy and environmental instructions and practices as being core elements of IBM's EMS; it clearly defined roles and responsibilities of Corporate Environmental Affairs staff and the M&D locations; and it outlined what within the EMS needed to be documented.
Finally, as a third step, common solutions were developed and integrated into IBM's EMS to close any remaining gaps to ISO 14001 requirements. These solutions included:
A common procedure for identifying significant environmental aspects
All environmental aspects, activities, and environmental impacts of the corporation's operations were evaluated by a team of environmental experts to determine which aspects were to be considered "significant aspects," as required by the standard. Criteria for determining significance included such things as legal / regulatory and IBM requirements, environmental impact of the aspects, the commitment to be a responsible neighbor, and customer views.
Common training materials for executives, managers, and employees
These training materials contained all information needed for general training and awareness of ISO 14001 and IBM's worldwide EMS. The materials were sent to each ISO 14001 coordinator worldwide soft copy, who tailored them to site-specific circumstances, as necessary.
Guidance manuals
These included guidance for implementing the EMS, providing objective evidence during the internal and registration audit, and for understanding the registration process.
An EMS audit methodology
This included a question set that could be used by locations to conduct a complete EMS internal audit. Forms were included that covered writing a nonconformance, auditor notes, and the audit summary.
Although the worldwide EMS is designed to ensure that common requirements are met worldwide, each location has the flexibility to implement its management system in a manner that best suits its business needs and specific situations. This is important because site-specific business activities and environmental operations vary markedly from location to location.
Registration Process
Once implementation was well under way, the registration process became the key focus. At the onset of the process, IBM transferred four existing registrations that had been earned by individual M&D locations to the common registrar, BVQI, through surveillance audits - one site was already using BVQI as its registrar. And then IBM established an orderly schedule for having all remaining locations proceed through the audit process. Once BVQI audited a required percentage (over 25%) of locations plus Corporate Environmental Affairs staff, sampling criteria would allow us to receive the first edition of our the single registration. In fact, IBM supported its initial registration with successful registration audits of approximately 40% of its M&D locations. As mentioned earlier, all 26 M&D locations that were in our two-year plan are part of the worldwide registration, and two more locations that are just getting up and running are expected to be added in 1999.
The approach of pursuing a single registration was not without its challenges or drawbacks. Significant worldwide coordination was needed to ensure that all locations consistently and efficiently aligned their EMS's with ISO 14001 and the IBM Worldwide EMS Manual within a predetermined time frame. As a common registrar, BVQI quickly became very knowledgeable about IBM's EMS requirements, and there was an expectation for all locations to meet adequately and completely all requirements. Essentially, all locations were required to have a well structured, mature EMS in place at the time of the registration audit. Thus, IBM's established registration process and schedule left no room for locations (even the new ones) to avoid or delay deployment of the company's global EMS. In effect, by having a single worldwide registration, IBM has placed more stringent requirements on itself than what is typically expected during an ISO 14001 registration assessment. Nonetheless, the process has proven effective for validating IBM's commitment to a common EMS worldwide.
In addition, to the coordination demands of a single worldwide registration, some locations found that IBM's unique approach made it difficult from them to integrate their ISO 14001 registration with existing ISO 9001/2 registrations. Corporate did not encourage or discourage the integration of ISO 14001 with the 9000 systems, but instead allowed locations to evaluate and implement systems that suited their site-specific circumstances and business needs. Typically, those facilities that have more than one ISO 9001/2 registration covering discrete lines of business found that integration of the two systems was impractical. Those that found it advantageous to integrate the two management systems had to coordinate registration schedules and use of the single worldwide ISO 14001 registrar.
Tangible Benefits
Despite challenges and drawbacks mentioned above, nothing in IBM's experience would cause us to change our decision to support ISO 14001. From firsthand experience, IBM can answer skeptics fears defined above. First, we have not found the standard to be bureaucratic, nor have we been obliged to develop unneeded procedures. In fact, we found that some amount of structure and documentation is necessary to: (a) ensure environment is integrated through the fabric of the business; and b) to ensure that the EMS is based on a solid, documented framework of procedures and processes rather than individual knowledge, thus being immune to changes in personnel.
And second, as far as ISO 14001 not assuring environmental improvement worldwide, only time will tell. Although IBM has been working toward our worldwide registration for just over two years, were it not for ISO 14001, we would not have validated that all M&D locations consistently and effectively meet the requirements of our EMS. As a result of this validation, and in our quest for environmental leadership, IBM likes its chances for continual improvement - including improvement of the EMS and environmental performance - much better with ISO 14001 behind us. That's not to say IBM would not improve without ISO 14001. We certainly would. But, we think that greater improvements are possible with the ISO 14001 discipline. If tools make the job easier (and in our experience they do), then we prefer to use the ISO 14001 tool rather than leave it on the shelf.
After implementing ISO 14001 at 26 M&D locations and Corporate Environmental Affairs, and achieving a worldwide registration, IBM has been able to assess the value of these processes, and we can state with confidence that we have experienced tangible benefits. These benefits include the following:
ISO 14001 has made IBM's environmental management process "system dependent" rather than "person dependent." Since environmental professionals are typically technical specialists, they tend to have a plethora of regulatory, process, and procedural knowledge. Unfortunately, little of it is usually documented. Thus, if the specialist leaves the company, that knowledge is lost. ISO 14001 provides the impetus to document important requirements, procedures, and processes which are the backbone of the EMS, thus strengthening the system.
Employees (from top to bottom!), as well as on-site contractors, who did not traditionally see themselves as needing to be involved with the environmental management process now become knowledgeable of the company's environmental policy and their role in supporting it. They also learn of environmental aspects and impacts of the company's activities, products, and services, as well as the company's documented objectives and targets. Once made aware of the EMS and their part in it, IBM has found that these employees and contractors are surprised and pleased to find that they can and should actively contribute the company's environmental improvements.
ISO 14001 provides the framework for integrating environment into the fabric of the business. Executives often admit that this is one of the biggest challenges they face, and the ISO 14001 tool takes on this challenge very effectively.
Setting environmental objectives and targets - which are based on significant environmental aspects and impacts and not just on legal / regulatory requirements - has definite value within the framework of an EMS because the standard requires that these objectives and targets be monitored and measured within a preset program. It also requires designation of a person responsible for meeting the objectives and targets, as well as a definition of the means and time frame for achieving these. This fosters accountability and adds emphasis to environmental goals of the corporation through the monitoring and measurement program. As the adage goes, "What gets measured gets managed."
From a cost, and time, efficiency standpoint, the single worldwide registration provides IBM with a great advantage, since IBM is now able to conduct surveillance audits using a sampling process.
Global registration to ISO 14001 has enabled IBM to handle customer inquiries about environmental responsibility efficiently.
The European Union is openly encouraging companies to register to ISO 14001 or the European Management Audit Scheme (a standard very similar to ISO 14001), and many governments in Asia Pacific, in particular Japan, view the standard very favorably. Even the US EPA is starting to study the environmental benefits of implementing an EMS as it assesses the appropriateness of offering some regulatory relief to registered companies in the future.
Impacts in the Marketplace
Although it is still too early to evaluate fully the effects that ISO 14001 will have on marketplace advantage, some geographies have already enthusiastically embraced the standard. These include Asia Pacific, with Japan having over 25% of ISO 14001 registrations worldwide, and Europe. Indeed IBM, as a large multinational company, has felt customer pressure for registration in these geographies. One international company for which IBM is a supplier gives points on their satisfaction survey for having a registration to ISO 14001. Indeed, many companies worldwide are finding it advantageous to align their EMS's with the standard and register as customer needs require.
Continual Improvement
One very important element of ISO 14001 is that the EMS must continually improve. In essence, the standard requires sound environmental management to be a way of travel and not a destination. As a continual improvement activity and because we believe that ISO 14001 adds value to an EMS, even a mature one. IBM issued a letter to all its suppliers encouraging them to implement an EMS that aligns with ISO 14001 and to consider registration. IBM is committed to doing business with environmentally responsible suppliers and believes that, not only can ISO 14001 help a company improve its environmental performance, it can help IBM select suppliers who have the ability and the commitment to protect the environment. Other continual improvement activities include continued focus on the integration of contractors into the EMS worldwide and the development and deployment of a Corporate web page that documents IBM's worldwide EMS. Although ISO 14001 is not the only way to effectively manage environmental affairs, and registration to ISO 14001 does not itself guaranty outstanding environmental results, IBM's experience with the standard has shown that it, in fact, has provided strength and consistency to the overall environmental posture of the company.