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    TABLE OF CONTENTS

    Preface ..................................................................................................................................... 3

    Acknowledgements .................................................................................................................. 5

    Executive Summary .................................................................................................................7

    Environmental Management Systems in the nited !ingdom ................................................."3

    Environmental Management Systems# $e%ort on .S. &m%lementationand Policy 'evelo%ments ........................................................................................................ ("

    &S) "*++"# A ,ia-le Pu-lic Policy ool to Achieve Sustaina-ility in /a%an ............................3"

    EMAS0 &S) "*++" and Policy &m%lications in Euro%e ............................................................. 37

    he 1etherlands and 2ermany# wo Euro%ean A%%roaches to EMS Policy ...........................*3

    2lossary of erms ....................................................................................................................*7

    $eferences................................................................................................................................ *

    Appendices

    A%%endix " 4 1etherlands and 2ermany..................................................................... 53A%%endix ( 4 he anadian Ex%erience with EMS.....................................................5A%%endix 3 4 nited States..........................................................................................63A%%endix * 4 /a%an..................................................................................................... 67A%%endix 5 4 Ma8or ountry Summary Matrix9.........................................................6

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    PREFACE

    :o -e inserted -y ;&PSA2E? s%ent nearly two years studying =S 775+ and other national EMSstandards to determine the need for a standardiCed a%%roach concerning environmentalmanagement. he nited !ingdom0 and more s%ecifically =S&0 -ecame the secretariatorganiCation within &S) echnical ommittee (+7Dthe international grou% of ex%erts created todevelo% the &S) "*+++ seriesDto lead the charge to develo% &S) "*++".

    A num-er of initiatives have emerged in the nited !ingdom lately linking governmental %olicyto EMSs. hese include the 'e%artment of Environment and rade >'E$? and the 'e%artmentof rade and &ndustry >'&? actively su%%orting &S) "*++"EMAS in all its %olicy. =oth areactively referenced in "s Sustaina-le 'evelo%ment Strategy entitled A =etter Fuality ofGife.

    A new %artnershi% -egan in Gondon to link industry0 government and environmental grou%scom%letely through the use of EMSs0 &S) "*+++ and other sustaina-le -usiness %ractices. heS&2MA Pro8ect >Sustaina-ility &ntegrated 2uidelines for Management?0 was created -y thenited !ingdomBs '&0 =S&0 the Horum for the Huture and the &nstitute of Social and Ethical

    Accounta-ility >&SEA?. he S&2MA Pro8ect ho%es to esta-lish a strategic managementframework for sustain a-ility within the next two years. &ncor%orating the conce%ts ofenvironmental and social accounta-ility re%orting and other sustaina-le -usiness %ractices0

    United States

    Iistorically0 the nited States has led the world in successfully defining contem%oraryenvironmental %rotection. hese environmental gains have -een achieved at great cost throughheated legal and %olicy de-ates characteristic of the S environmental movement. A com%lexand im%erfect assem-ly of command and control re@uirements has -een effective over the %ast(+ years0 -ut dramatic turns in the economy and unforeseen changes in manufacturing suggestthat more ada%tive0 %erformanceD-ased environmental management methods are needed.

    ou%led with a%%ro%riate environmental standards0 verifia-le audits and %u-lic re%orting ofresults0 EMSs offer an ada%tive su%%lement to com%lianceD-ased regulatory efforts in the Sand can facilitate the achievement of common sustaina-le environmental %rotection goals. he

    %olicy dialogue in the nited States views EMSs as an im%ortant emerging tool that hold%otential for linking -usiness logic with environmental goals and res%onsi-le stewardshi% foractual environmental im%rovements -eyond what the %resent configuration now offers. As thePresidentBs ouncil on Sustaina-le 'evelo%ment >PS'? said0 :aincluding %ro%erly certified &S) "*++" systems? do not necessarilyensure im%roved environmental %rotection and %erformance. $ather0 effective EMSs can%rovide significant structural su%%ort for im%roving %erformance if cou%led with @ualitative and@uantitative %erformance commitments and goals.

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    &n the nited States0 &S) "*++" im%lementation and certification was slow to take off ascom%anies took a wait and see a%%roach to the standard. his was due to a num-er ofreasons0 which included mixed regulatory signals from the EPA and state enforcement -odies0as well as limited outreach efforts -y the American -odies res%onsi-le for the develo%ment ofthe &S) "*+++ seriesDthe American 1ational Standards &nstitute and the S echnical Advisory2rou% to echnical ommittee (+7 =ut -y "J0 &S) "*++" certification num-ers in the nitedStates -egan to increase significantly0 with larger com%anies such as the &=M or%.0 Hord Motoro. and Gockheed Martin certifying to the standard.

    =y the end of " there were more EMS initiatives from the %u-lic sector0 and EMS continuedto gain ground as a %olicy tool. he use of certifia-le EMSs has -ecome a key element in mostvoluntary %rograms and initiatives develo%ed -y governments. 1ew /ersey0 )regon andMassachusetts0 and S EPA#s Star rack %rogram all utiliCe EMSs as the -asis for %artici%ationin their advanced com%liance %rograms. he linton Administration issued an executive order inlate " that re@uiring all federal agencies to -egin environmental management system %ilot%ro8ects -y March 3"0 (++(0 and to esta-lish an effective EMS at all federal facilities -y (++5.

    )ther significant %olicy initiatives em-racing the EMS framework include reinvention activitiesat EPA0 and the final re%ort of the S PresidentBs ouncil on Sustaina-le 'evelo%ment in May". EPA has also issued two re%orts concerning EMSs including a strong commitment to

    utiliCing environmental management systems a%%roaches0 the first such clearly %roactivestatement on EMS from EPA0 and a further agency commitment to develo% a %erformance trackor alternate regulatory %athway. EPA also released the agencyBs Action Plan for EMSs. his new%lan is the most com%rehensive %olicy a%%roach concerning &S) "*++" to date in the nitedStates0 and will likely garner significant discussion and de-ate in the early months of (+++.

    Japan

    /a%an leads the world -y a wide margin in terms of the num-er of com%anies certified to the &S)"*++" international environmental management systems standard0 nearing the 30+++ mark as of/anuary (+++. /a%anBs ma8or cor%orations are on -oard0 setting good exam%les with EMSim%lementation and encouraging other firms to -ecome registered with guidance and alessonsDlearned a%%roach. he electric a%%lianceconsumer electronics industry is res%onsi-lefor the ma8ority of certifications in /a%an0 with *+ %ercent of the market0 followed -y the chemicaland trans%ortation sectors. /a%an is also an early leader in getting -eyond its own -orders0 withits ma8or com%anies even seeking &S) "*++" certification in overseas facilities0 in %laces like thenited States0 Asia and Euro%e.

    =ecause of this tremendous u%take of the &S) "*++" standard0 /a%an is a fundamental casestudy to understand the various %arameters driving the %rocess of &S) "*++" im%lementationand %olicy making. /a%anese industry and the Ministry of &nternational rade and &ndustry >M&&?learned from the costly lesson of delayed conformity with &S) +++. hus0 when &S) "*+++develo%ment -egan0 the /a%anese government and the industries with technology andman%ower0 took the initiative in sha%ing /a%anBs res%onse. /a%anese industries took %art in the%rocess through s%ecial task forces set u% in the /a%an Hederation of Economic )rganiCations>the !eidanren? and other industrial -odies. /a%an was one of the first countries to fullyem-race the EMS standards0 and M&&Bs su%%ort and %ush was one of the crucial elements.

    /a%anBs geogra%hy and demogra%hy may also -e %laying a role in ado%tion of &S) "*++". As asmall island nation with limited natural resources0 /a%an im%orts most of the raw materials andenergy it uses. /a%anBs land area is almost e@ual to that of alifornia -ut -ecause of themountainous terrain0 only "*K of the land is ha-ita-le. Moreover /a%anBs %o%ulation is a-out halfof the nited States0 whereas the S has 3+ times more land area than /a%an0 thus0 making/a%an a densely %o%ulated nation much like the 1etherlands. he result is that /a%an is realiCingthe im%ortance of environmental %reservation for the current and future generations. he!eidanren >Hederation of &ndustrial Association of /a%an? %u-lished the 2lo-al Environment

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    harter in ""0 which called for voluntary action toward good environmental management. &naddition to voluntary action the harter stresses the need to reconfirm environmental ethics andecoDefficiency through innovative technology and economic efficiency. Since its announcement0the !eidanren harter has -een the guiding %rinci%le in /a%anese industry.

    European Union

    urrently0 the full mem-ers of the Euro%ean nion >E? are Austria0 =elgium0 'enmark0 Hinland0Hrance0 2ermany0 2reece0 &reland0 &taly0 Guxem-ourg0 the 1etherlands0 Portugal0 S%ain0Sweden and nited !ingdom. )ther countries are vying for accession to E mem-ershi%0including former SovietD-loc countries. E mem-ershi% is an attractive economic o%tion forthese countries0 making environmental %erformance DD and hence EMS im%lementation DD an Eaccession issue.

    he E has ado%ted as its management system EMAS >he EcoDAudit and ManagementScheme?. he aim of EMAS0 the Es EcoDAudit and Management Scheme0 is to %romoteonDgoing im%rovements in the environmental %erformance of com%anies and the %rovision ofenvironmental information to the %u-lic. &t is a sectorDs%ecific standard0 o%en only tomanufacturing sites. o certify to EMAS0 a com%any must ado%t an environmental %olicy0 reviewenvironmental %erformance at the site in @uestion0 develo% an environmental management

    system -ased on &S) "*++"0 develo% a %lan of action in light of the findings of theenvironmental review0 audit the system and %u-lish a statement of %erformance of the site. A@ualified third %arty checks the system and the statement to see if they meet stated EMASre@uirements in the standard. &f so0 they are validated and the site can -e registered. ;hen ithas -een registered0 the site gets a statement of %artici%ation0 which it can use to %romote its%artici%ation in the scheme.

    Gike &S) "*++"0 EMAS re@uires the com%any to s%ecify environmental o-8ectives at all relevantlevels within the com%any that are consistent with its %olicies. he o-8ectives must -e set at thehighest a%%ro%riate management level0 aimed at the continuous im%rovement of environmental%erformance. =ased on findings from the audit0 EMAS re@uires management to set highero-8ectives and to revise the environmental %rogram to -e a-le to achieve those o-8ectives. hisste% is analogous to the management review of &S) "*++". =ut a ma or difference -etween &S)"*++" and EMAS is that EMAS re@uires the com%any to examine and assess the environmentaleffects of the its activities at the site and com%ile a register of significant effects. his register isnot re@uired in &S) "*++".

    &n its first version0 %u-lished in "30 EMAS consisted of (" Articles and 5 Annexes. he new0revised version0 called EMASD(0 will likely -e %u-lished in a streamlined format. he EMASrevision0 now called EMASD(0 is ex%ected to -e %u-lished in (+++. he main elements of therevised EMASD( are#

    he extension of the sco%e of EMAS to all sectors of economic activity including localauthorities

    he integration of &S) "*++" as the environmental management system re@uired -y EMAS

    he ado%tion of a visi-le and recogniCa-le EMAS logo to allow registered organiCations to%u-liciCe their %artici%ation in EMAS more effectively the involvement of em%loyees in theim%lementation of EMAS and

    he strengthening of the role of the environmental statement to im%rove the trans%arency ofcommunication of environmental %erformance -etween registered organiCations and theirstakeholders and the %u-lic.

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    he goal of sustaina-le develo%ment0 which is now integrated into the Euro%ean niono-8ectives0 calls for the use of a wider range of tools for environmental %olicy0 such as EMAS.he 5th ommunity Environmental Action Plan recogniCes this and clearly indicates thatenvironmental res%onsi-ility should -e shared -etween authorities0 industry0 consumers and thegeneral %u-lic.

    Netherlands and Germany

    he 1etherlands and 2ermany are -oth leaders in the use of EMSD-ased a%%roaches for %olicy0regulatory and management %ur%oses. Since they are -oth mem-ers of the Euro%ean nion0-oth nations are su-8ect to the voluntary regulation of EMAS. &n terms of EMS %olicya%%roaches and regulatory instruments0 however0 these countries %resent @uite different ande@ually interesting %rograms0 each tailored to -uild u%on their res%ective existing legalframeworks and economic conditions

    he 'utch 2reen Plan is formally known as the 1ational Environmental Policy Plan. he currentversion of the %lan is generally referred to as 1EPP 3. he %lan is com%rehensive0 longDtermand interdisci%linary. Es%ecially significant is the 1EPPs reliance on a management frameworkto ensure %racticality and functionality. he em%hasis on good management in the 1EPP has%aved the way for the ra%id u%take of EMS in the 1etherlands. he soDcalled covenant

    a%%roach is the 'utch model of sectorDs%ecific and facilityDs%ecific regulation0 organiCed throughthe heavily negotiated0 finely tailored contractual agreements known as covenants. ;hile thecovenant a%%roach does not automatically im%licate the use of EMS0 most of the %artici%atingsectors and facilities have recogniCed the value of the EMS in the covenant model and haveincor%orated the EMS conce%ts into their initiatives.

    &n contrast to the 1etherlands0 which has a high level of EMS im%lementation0 -ut with arelatively low level of %artici%ation in EMAS0 2ermany has used EMAS as its %rimary vehicle forEMS im%lementation. 2erman industry wants that flexi-ility the 2erman regulators want to findmechanisms to %rovide that flexi-ility while %reserving accounta-ility. =oth sides view theEMSD-ased EMAS %rogram as %roviding a mutually acce%ta-le vehicle. his 8oint %osture ofgovernment and industry has resulted in an enormous level of acce%tance of EMAS in 2ermany.Partici%ation in EMAS is seen as demonstrating a su%erior level of environmental %erformancethrough a voluntary mechanism. &n =avaria0 for exam%le0 this has led to the su-stitution orsim%lification a%%roach through ecoDmanagement. Administrative mechanisms are -eing used todefine the range of %ermissi-le su-stitution or sim%lification through EMS.

    Canada

    anada has -een very active in the &S) "*+++ %rocess0 chairing (+7. he national standards-ody0 the anadian Standards Association has a very %roactive outreach %rogram and hasdevelo%ed excellent su%%lementary materials. he 1ational $oundta-le on the Environment andthe Economy >1$EE? is res%onsi-le for anadaBs accreditation and ca%acityD-uilding effortsrelated to EMS. =ut the S is anadaBs %redominant trading %artner0 and since S com%anieshave not considered EMS as much of a re@uirement as from /a%an0 ! or 2ermany0 so anadahas -een relatively slow to em-race EMS. he im%lementation %icture a%%ears to -e %oised for

    a dramatic change.

    Gooking -eyond the raw certification num-ers0 the true im%act of EMS standards in anada ismuch greater since many com%anies use &S) "*++" as a -enchmark to review their existingsystems or to %rovide uniformity across several facilities within a com%any.B Many of these sameorganiCations have decided to wait to move to the certification stage until additional incentives0whether regulatory or customerDdriven0 a%%ear. /ust recently0 therefore the Hord and 2&,&actions are sending interest and demand u% and down the su%%lier chain. )ntario in %articular isthe center of auto %arts and auto manufacturing in anada and is feeling -ig im%act in (+++.

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    &n anada0 &S) "*++" is %roving invalua-le as a measure of a%%ro%riate due diligence forcor%orate environmental %rograms. anadian 8udges have welcomed the advent of aninternational0 thirdD%arty certifia-le standard for environmental management systems. anadiancourts have used &S) "*++" in several cases to date. he Pros%ec hemical case0 decided in

    Al-erta0 drew wides%read attention0 not only in anada -ut also in the S for its innovativesettlement a%%roach utiliCing EMS re@uirements. anadian cor%orate environmental %rogramshave looked at this case as signaling the acce%ta-ility of &S) "*++" to courts and to theregulators. Gater this year0 the new anadian Environmental Protection Act will come into force.hat statute has an interesting %rovision0 -asically ado%ting as law the notion that courtsentences may include the re@uirement of im%lementing an EMS along the lines of arecogniCed international standard.

    EMS is -ecoming recogniCed as a tool for moving towards sustaina-ility. anada has -een muchmore rece%tive to -uilding u%on a sustaina-ilityDoriented framework than their S neigh-ors. hesustaina-ility conce%t is ex%licitly -uilt into a num-er of government and %rivate sectorinitiatives. &n turn these %rovide vehicles for EMS im%lementation. )ne of the most significantsustaina-ility develo%ments in anada is the re@uirement that each Hederal Ministry %re%are aSustaina-ility Plan. he %u-lic sector is making the commitment to show the way forward onsustaina-ility in anada.

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    ENVIRONMENTAL MANAGEMENT SYSTEMS IN THE UNITED KINGDOM

    BS 7750 The British Undepinnin!s "# Environmental anagement

    =efore -eginning down the long trek of understanding the develo%ment and im%lementation ofEMS and its %otential effects on %u-lic %olicy0 it is im%erative to know and understand the historyof the &S) "*++" standard and environmental management systems >EMSs? in general. henited !ingdom is a critical element to the EMS %uCCle0 -ecause it is in this country that theEMS 8ourney -egan with the a%%earance of the first national EMS standard in the early "+s.

    Additionally0 the !Bs overall history is im%ortant -ecause all of the ongoing initiatives discussedin this section have a direct link to the future environmental %olicy of the nited !ingdom andmany other countries around the world. he nited !ingdom continues to -e the worldBs leaderwith EMS initiatives.

    Some o-servers trace the genesis of environmental management systems and the &S) "*+++series to the "7( nited 1ations onference on Iuman Environment held in Stockholm0Sweden0 which ultimately s%awned a "J7 re%ort titled Our Common Future. his re%ortcontained the first reference to Lsustaina-le develo%ment. alling for industry to develo%effective EMS to hel% manage their im%act on the environment. =y the end of "JJ0 more than

    5+ world leaders had %u-licity su%%orted the re%ort. he nited 1ations then convened the .1.onference on Environment and 'evelo%ment D the Earth Summit D in $io do /aneiro in /une"(.

    o %re%are for that summit0 the &nternational )rganiCation for StandardiCation >&S)? in 2eneva0SwitCerland0 esta-lished the Strategic Advisory 2rou% on the Environment >SA2E? in ""0 tomake recommendations regarding international standards for the environment. After muchdiscussion and de-ate0 the $io Summit and the SA2E meetings eventually -egan to solidify theconce%t of an EMS standard that could -e utiliCed across all industry sectors on a glo-al scale.

    At that time0 efforts to create a single0 generic0 internationally recogniCed EMS standard were>and still are? driven -y the desire among com%anies to avoid du%licative Dand sometimescom%etitiveDcor%orate and governmental %rograms0 and -y the need for o-8ective validation oftheir commitment to the environment.

    Such efforts -egan on several fronts glo-ally0 -ut one clearly led the way to &S) "*++"0 theworldBs most visi-le and recogniCa-le standard for environmental management. &n the early"+s in England0 the =ritish Standards &nstitution >=S&? develo%ed British Standard 7750:Environmental Management Systems, as a com%anion to its =S 575+ standard on @ualitymanagement systems. =S 575+ was the forerunner and tem%late for the &S) +++ @ualitymanagement system standards0 which gained huge %o%ularity for organiCations of all ty%es andsiCes to esta-lish @uality management at all levels of %roduction.

    =S 775+ was the national EMS standard for the nited !ingdom0 -eginning in "(. Along withother national standards0 including those develo%ed -y /a%an0 anada0 &reland0 S%ain andHrance0 =S 775+ eventually formed the -asis of &S) 14001 develo%ment. &n fact0 the nited!ingdom0 and more s%ecifically0 =S&0 -ecame the secretariat organiCation within &S) echnicalommittee (+7Dthe international grou% of ex%erts created from the SA2E meetings to develo%

    the &S) 14000 seriesDto lead the charge to develo% &S) 14001.

    ountries %artici%ating in SA2E0 which included most of the industrialiCed and develo%ing worldeconomies0 s%ent nearly two years studying =S 775+ and other national EMS standards todetermine the need for a standardiCed a%%roach concerning environmental management.

    he reason to develo% =S 775+ >first %u-lished in "(?0 and ultimately0 &S) 14001 >%u-lished in"6?0 was threefold for ! industry and government#

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    ". he %assage of the ! Environmental Protection Act in "+

    (. he early draft of the Euro%ean nionBs >EBs? EcoDManagement and Audit Scheme >EMAS?%rogram in 'ecem-er "+ >%u-lished in "3 and u% for revision again in (+++? and

    3. Pressure from the %u-lic and %oliticians concerning the environment.

    he -asic goals of =S 775+ were to validate a com%anyBs com%liance with its statedenvironmental %olicy and to re@uire that the com%any demonstrate that com%liance to others. &twas also written s%ecifically to -e com%ati-le with the &S) +++ series on @uality managementand with the re@uirements of the EBs EMAS0 which will -e discussed later in this %resentation.

    =S 775+Bs first draft was develo%ed @uickly in the nited !ingdom to address the needs of themarket0 and was involved in a %ilot %rogram with over 3++ com%anies within "( months of theconce%tion stage. >onversely0 &S) 14001 took four years to develo% and %u-lish its first draft.?

    !e"ining Environmental anagement

    Eventually0 ex%erts in the nited !ingdom and around the world took the conce%t of =S 775+and develo%ed the scheme of a standardiCed EMS called &S) 14001. hose ex%erts defined the

    EMS conce%t as the as%ect of an organiCationBs overall management structure that addressesthe immediate and longDterm im%act of its %roducts0 services and %rocesses on the environment.Additionally0 that conce%t ho%ed to %rovide order and consistency in organiCationalmethodologies through the allocation of resources0 assignment of res%onsi-ilities0 and ongoingevaluation of %ractices0 %rocedures and %rocesses.

    he idea worked0 and @uickly caught on in 2reat =ritain and in other %arts of Euro%e0 as %u-licconcern over industryBs im%act on the worldBs environment increased. &ndeed0 %u-lic o%inion onthe environment continues to -e a ma8or driver for E&,&Ss. hen and today0 %olitically oriented-odies0 such as environmental advocacy organiCations0 watchdog grou%s and the green %artythat esta-lished a foothold in the =ritish Parliament0 urged -usinesses to take res%onsi-ility fortheir environmental effects. his %ressure from the %u-lic sector led to a rise in %ro%osed andenacted environmental legislation worldwide.

    =ut there was great concern over the ado%tion and certification of too many different standardsin the Euro%ean and glo-al markets0 which many feared would lead to trade -arriers -etweennations and costly and often du%licative systems to address environmental concerns. hiseventually led to the ado%tion of &S) "*++" not only in the nited !ingdom in "60 -ut alsothroughout Euro%e and 1orth America soon after.

    &t was not an easy transition0 however0 to make the switch from =S 775+ to the international &S)"*++". &n the early "+s0 many viewed =S 775+ as -eing more %rescri%tive than &S) "*++".&S) "*++" incor%orated many of the re@uirements of =S 775+ as an a%%endix0 which makesthem guides only0 not re@uirements.

    Hor exam%le0 =S 775+ did not s%ecifically re@uire that com%anies %u-licly discloseenvironmental %erformance informationD-ut the language strongly leaned in that direction. As it

    is currently written0 &S) "*++" re@uires organiCations to communicate their environmental%olicies to interested stakeholders0 -ut does not re@uire %u-lic disclosure of environmentaleffects. Iowever0 a list of environmental effects is included in an annex to &S) "*++" assuggested items to consider during im%lementation.

    &ndeed0 economic indicators are increasingly -ecoming a ma8or factor for im%lementation andcertification of &S) "*++" for industry. &n fact0 in 1ovem-er "0 the (0++ mem-ers of theGondon Stock Exchange announced that they would re@uire annual re%orts from its firms in (+++

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    to detail how they identify and co%e with financial0 environmental and other risks in order to -elisted on the exchange.

    The Current #S$ %&00% S'enario and the E'onomy

    HastDforwarding to the current environmental situation and &S) "*++"Bs role in the nited!ingdom0 the effect has -een su-stantial to -usinesses of all ty%es0 government agencies and tothe environment itself.

    2lo-ally0 environmental awareness0 es%ecially in the Euro%ean nion0 ex%erienced a dramaticsurge in the "+s0 as technology allowed more information to -e distri-uted at a much fasterrate to consumers and investors.

    Similarly0 organiCations that affected the environment em-raced &S) "*++" and environmentalmanagement as a %otential res%onse to that awareness0 in terms of communication >as aregistered com%any to an internationally recogniCed standard? and as a new0 innovative avenueto address legal concerns.

    Since Se%tem-er "60 when &S) "*++" was %u-lished0 an estimated "30+++ organiCationsaround the world have im%lemented and received an inde%endent0 third %arty certification of that

    system -y an accredited registrar. he nited !ingdom accounts for an estimated "0+++certifications0 currently ranked third -ehind /a%an and 2ermany with the highest num-er ofcertifications.

    =ut these figures0 some ex%erts say0 are only a @uick glim%se at &S) "*++" trends. ;hile thesefigures do re%resent a measurement of actual certifications0 some ex%erts -elieve a moreso%histicated measure can -e o-tained -y taking into account a countryBs level of economicdevelo%ment0 as measured -y gross domestic %roduct >2'P?0 %o%ulation statistics0 as well asthe num-er of certifications.

    Sim%le certification counts acknowledge some trend information >for exam%le0 theelectricalelectronics0 chemicals0 steel and car manufacturing industries re%resent the largestnum-er of certifications from that data0 >most likely -ecause those industries often have thegreatest im%act on the environment and to the worldBs natural resources?. =ut that informationdoes not account for the %ractice of environmental management itself0 or the many factors thatmay account for the certification num-er differences -etween countries0 such as su%%lyDchain%ressure0 regulatory concerns and other factors that weigh heavily on industry in differentsectors.

    Additionally0 a%%lying economic indicators to those figures gives the num-er of certifications forto% countries a different look# /a%an is "st -y num-er of certifications0 "3th -y %o%ulation0 and"Jth -y 2'P he nited !ingdom0 on the other hand0 is 3rd0 "*th and "7th res%ectively0 and thenited States0 7th0 Jth and 37th0 according to information %rovided -y the Iungarian Associationfor Environmentally Aware Management.

    &ndeed0 economic indicators are increasingly -ecome a ma8or factor for im%lementation andcertification of &S) "*++" for industry. &n fact0 in 1ovem-er "0 the (0++ mem-ers of the

    Gondon Stock Exchange announced that they would re@uire annual re%orts from its firms in (+++to detail how they identify and co%e with financial0 environmental and other risks in order to -elisted on the exchange.

    his move -y the &nstitute of hartered Accountants >&A? in England and ;ales is aconse@uential ste% toward holding directors and managers accounta-le for significantenvironmental0 ethical and social risks as well as financial threats. &t also is an im%ortant movetoward making a firmBs environmental infrastructure more trans%arent in ways that -etter informinvestors0 lenders and insurers.

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    At least 5++ firms with head@uarters outside the nited !ingdom are listed0 including many fromthe nited States. .S. sectors re%resented include automotive0 %harmaceuticals0 finance0energy0 electronics and communications. he Gondon Stock Exchange is the fourth largest in theworld as measured -y market value0 following 1ew Nork0 1AS'AF and okyo. he 'ow /onesin the nited States also created a similar index of environmental information for the samereasons in )cto-er ". >See nited States summary for more information.?

    he %ower of the Gondon Stock Exchange rule is in the information it re@uires as much as inactual com%any %erformance on environmental factors. Hor exam%le0 the stock exchange willallow com%anies to say why they are out of line with the risk management re@uirement0 -ut it isex%ected that such admissions risk the financial -ottom line or consumer confidence.

    Ex%erts say the re@uirement will force this ty%e of risk visi-ility onto the -oard room agenda0ultimately changing attitudes with cor%orations and investors. Additionally0 they say more %u-licinformation regarding the environment will add credi-ility to the organiCationBs re%utation forsuccess.

    &n the nited !ingdom0 a good exam%le of that re%utational risk was that of Shell )il0 whichreceived harsh criticism in the "+s for its dealing with la-or and human rights issues in the

    country of 1igeria and the decommissioning of an oil %latform in the 1orth Sea. he com%anyBsstock %rice %lummeted following the news when shareholders assaulted ShellBs =oard of'irectors for immediate action in Gondon in May "7. hat confrontation %roduced Shell%olicies that included greater shareholder and stakeholder access to information regarding theenvironment.

    he Shell =oardBs commitment to acce%t ultimate res%onsi-ility for environmental and ethicalconduct received excellent review in the following months. Since "70 systems0 includingenvironmental management systems0 can fit into the %lans of those %rofessions.

    Similar to &S) "*++"0 the &A code of the Gondon Stock Exchange re@uires clear0 measura-leo-8ectives0 8ust as many legislative %olicies do glo-ally. S%ecial attention is %aid to significantrisks0 -ut care is advised to avoid creating new -usiness -ureaucracies and excessive%a%erwork.

    Similar to EMAS0 Euro%eBs environmental management system0 the &A code carves out astrong role for em%loyees in the managing of environmental risk and achievement ofenvironmental %erformance. &t asks the com%any to communicate to its em%loyees what isex%ected of them and the co%e of their freedom to act.

    Environmental %rotection is es%ecially mentioned as an area where em%loyees have theknowledge0 skills and tools to su%%ort the achievement of the com%aniesB o-8ectives0 includingthe legal arena.

    his is a key area of develo%ment for all involved in &S) "*+++ and EMSs in general. ;ith &A0em%loyees must have esta-lished channels to re%ort sus%ected -reaches of laws orregulations#B and strong attention is %aid to the need for em%loyees and management to com%ly

    with the code0 ena-ling them to %roduce an honest and com%lete re%ort to the Stock Exchange.1oncom%liance with the re%orting code will result in an em-arrassing disclosure0 which couldattract the attention of the %ress0 shareholder activities and institutional investors#B according to&A.

    Environmental (eporting and the ES )in*

    he recent develo%ments at the Gondon Stock Exchange0 the &A ode and the 'ow /ones arethe direct result of the worldBs need to o-tain more and more credi-le data regarding the

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    environment0 environmental management and other riskD-ased assessments.9 &nvestors0consumers and the general %u-lic now have increased access to relevant data to make moreinformed decisions with financial investments as well as the %roducts for %urchase. hesestakeholders are 8ust -eginning to -ecome aware of the %otential linkage -etween EMS andenvironmental re%orting.

    he conce%t known as environmental re%orting is0 in itself0 a growing trend in the nited!ingdom and throughout the world0 es%ecially with large0 multinational organiCations. &n fact0according to a recent re%ort issued -y Pensions and &nvestment $esearch onsultants in thenited !ingdom0 65 %ercent of com%anies re%ort in some form on environmental issues0 -ut notin ways that are com%ara-le or consistent. he re%ort also states that environmental re%orting ismore develo%ed among HSE "++ firms >J %ercent? than HSE (5+ firms >55 %ercent?. hereare wide sectoral differences# mineral extractionD"++ %ercent of firms oil ex%loration and%roductionDJ6 %ercent 57 %ercent of the electrical and electronic e@ui%ment sector 33 %ercent offinancials and 6 %ercent of investment trusts. Another re%ort from !PM2 shows that a third ofthe worldBs (5+ largest com%anies0 mainly multinationals0 now %u-lish a standaloneenvironmental re%ort. here is a wide variation -etween sectors0 with higher re%orting levels inthose areas %erceived to have a greater %otential environmental im%act >%harmaceuticals0chemicals0 trans%ort0 etc.?. Additionally0 more recent environment re%orts %lace greaterem%hasis on em%loyee involvement0 su%%lier re@uirements and sustaina-le develo%ment than in

    the %ast.

    =ut again0 there is no standardiCed a%%roach to environmental re%orting0 and this issue hascaused significant de-ate within the &S) "*+++ community as to how0 and indeed if0environmental re%orting should -e linked to standardiCed EMSs. he argument is that the -eautyof &S) "*++"0 a voluntary standard0 is its flexi-ility to -e ado%ted -y any ty%e of organiCation toreduce environmental im%act and instill the conce%t of continual im%rovement throughout alllevels of the organiCation concerning waste reduction0 legal com%liance and myriad otherenvironmental issues. &ndustry ex%erts -elieve that this flexi-ility is one of the most im%ortantvalues of &S) "*++" and EMS im%lementation0 and if &S) "*++" -egins to %rescri-e mandatoryre%orting of environmental issues0 then the flexi-ility will -e lost and the ma8ority of smallD andmediumDsiCed enter%rises will not -e a-le to im%lement the standard -ecause of increased costsand augmented lia-ility issues.

    Iowever0 other ex%erts -elieve the conce%t of environmental re%orting is inevita-le in thelongDterm0 as the hunger for information continues to grow in this area. &S) "*++" ex%erts %lanto examine the issue during the revision %rocess0 already underway0 with ho%es of a revisedversion of &S) "*++" -y (++3.

    =ut many organiCations in the nited !ingdom already have initiated %lans to re%ortenvironmental information0 or have esta-lished %artnershi%s with relevant organiCations to%rovide the environmental data needed to make sound decisions. &n fact0 an a96reement wasreached in late " -etween the )rganiCation for Economic oo%eration and 'evelo%ment>)E'? nations to exchange environmental information -efore investing in large overseas%ro8ects. he intention is that -y exchanging such information0 investment in environmentallydamaging %ro8ects can -e avoided. he agreement is also a first ste% toward international ruleson ex%ort credits and the environmentDsomething that could have %rofound effects concerning

    the continuing de-ate on the "7 !yoto Protocol on limate hange issue for all nations0including /amaica.

    Many ex%erts0 including those within the nited 1ations Hramework onvention on limatehange >the grou% that devised the !yoto %act?0 -elieve &S) "*++" and others in the &S) "*+++series could %lay a significant role in re%orting relevant environmental information and reducinggreenhouse gas >2I2? emissions to the ProtocolBs stated o-8ectives.

    #S$ %&00% and +oli'y #mpli'ations in the United Kingdom

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    A$ In#%sin! EMS in&" P%'(ic P"(ic). A num-er of initiatives have emerged in the nited!ingdom lately linking governmental %olicy to EMSs. hey include#

    ". he 'e%artment of Environment and rade >'E$? and the 'e%artment of rade and&ndustry >'&? actively su%%ort &S) "*++"EMAS in all %olicy and -oth are activelyreferenced in "Bs Sustaina-le 'evelo%ment Strategy titled A =etter Fuality of Gife>%u-lished May ".?

    (. he 'E$Bs advice to those sites affected -y the new E 'irective on &ntegratedPollution Prevention and ontrol >&PP? is to im%lement the ! $egulations via anEMS >this will affect over 70+++ installations under ! $egulations0 including the foodand drink industry for the first time?.

    3. he Iealth and Safety Executive >ISE?0 the ! Iealth and Safety regulatory -ody0 isalso em%hasiCing the use of a cor%orate EMS to im%lement the ontrol of Ma8or

    Accidents and IaCards >)MAI? 'irective0 which came into force in A%ril ".

    *. Hollowing a re%ort -y the Environmental Audit >Select? ommittee into the 2reening2overnment &n@uiry0 the ! 2overnment has res%onded with a %olicy commitment that

    all ! government de%artments and next ste% agencies should ado%t EMSs with atleast one ma8or site %er de%artment covered -y certification -y (++". he committeealso recommended that all government de%artments should take a strongermanagement systems a%%roach.. to their %rocurement activities. his0 in effect0 %lacesthe onus on the ! government to green its E*+ -illion a year of %rocurement activityDama8or market driver to EMS im%lementation.

    5. he ! government is nearly ready to reDlaunch its Making a or%orate ommitment>MA? am%aign >originally focused on energy efficiency alone? with a wider focusaimed at getting ! -usinesses down the EMS route.

    6. he '&0 working with =S&0 8ust develo%ed a new EMS Small =usiness Scheme>EMS(SME? with a %ilot due to start in He-ruary (+++ with (5+ com%anies and *++individual training delegates. '& grantDinDaid su%%ort has -een %rovided for the %ro8ect.

    B$ EMS *nd S%s&*in*'i(i&) P"(ic)$ A new %artnershi% -egan an early develo%ment %hase latelast year in Gondon to link industry0 government and environmental grou%s com%letelythrough the use of EMSs0 &S) "*+++ and other sustaina-le -usiness %ractices.

    Pre%aring %roactively for the years ahead0 a federation of organiCations is now gearing u% tolaunch the second %hase of a %ro8ect that could someday -e the re%lacement standard for&S) "*+++0 Social Accounta-ility J+++ and the myriad other guidance documents nowa%%earing in the market%lace to achieve some level of sustaina-ility.

    &ts name is the S&2MA Pro8ect >Sustaina-ility integrated 2uidelines for Management?0 andits %otential to do for sustaina-ility what &S) "*+++ is doing for environmental managementin the nited !ingdom and other %arts of the world is @uite real.

    reated -y the nited !ingdomBs '&0 =S&0 the Horum for the Huture and the &nstitute ofSocial and Ethical Accounta-ility >&SEA?0 the S&2MA Pro8ect ho%es to esta-lish a strategicmanagement framework for sustaina-ility within the next two years. According to %ro8ectofficials0 %rogressive com%anies in the nited !ingdom and others worldwide already have agreat deal of ex%erience in tackling sustaina-ility issues0 -ut the lessons learned need to -edrawn out and translated into a generic framework that can -e a%%lied across industry as awhole. &t is the same scenario discussed earlier concerning =S 775+ and &S) "*++"0 only

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    incor%orating the conce%ts of environmental and social accounta-ility re%orting and othersustaina-le -usiness %ractices.

    '& officials say that thereBs a growing recognition in the market%lace concerning theenvironmental management systems the world now has0 including EMAS and &S) "*++".=ut the new %ro8ect ho%es to tackle not only the environmental %ro-lems of today andyesterday0 -ut also the as%ects of technology and the economy0 as well as the social and theethical s%heres of the future.

    According to newly released literature on the %ro8ect0 successful com%anies can no longerafford to ignore sustaina-ility. he %ressures are coming from all directions government0consumers0 communities and organiCed grou%sDfor -usinesses to -e more environmentallyand socially res%onsi-le and have higher ethical standards.

    At the same time0 the drive to -oost com%etitiveness and shareholder value for -usiness inthe nited !ingdom is stronger than ever.

    Sustaina-ility is all a-out striking a -alance -etween these different %riorities#B the %ro8ectBsdescri%tion states.

    he !Bs Sustaina-le 'evelo%ment Strategy0 %u-lished in May "0 defines sustaina-ilitywith four o-8ectives#

    Social %rogress that recogniCes the needs of everyone Effective %rotection of the environment Prudent use of natural resources and Maintenance of high and sta-le levels of economic growth and em%loyment.

    Scheduled to com%lete the sco%e develo%ment %hase in He-ruary (+++0 which includes acom%rehensive survey of existing tools and standards in the environmental0 social andeconomic fields0 followed -y a ga% analysis to identify where new work is re@uired0 theS&2MA Pro8ect %lans to head into the new millennium -y recruiting (5 organiCations toex%eriment with new tools and standards as they are develo%ed.

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    ENVIRONMENTAL MANAGEMENT SYSTEMS+ REPORT ON U$S$IMPLEMENTATION AND POLICY DEVELOPMENTS

    In&"d%c&i"n

    his section of the re%ort discusses current im%lementation trends and antici%ated %olicydirections in the evolving develo%ment and use of Environmental Management Systems >EMSs?in the nited States. he im%lementation exam%les and technical as%ects of EMSs in use in the.S. are diverse0 wides%read and referred to here only generally for the %ur%oses of discussingtheir increasing ado%tion. he thrust of this re%ort is to shed light on %olicy develo%ments at thestate and federal level regarding the %romotion of EMSs as a matter of %romoting environmentalim%rovement and further aligning it with economic efficiency.

    Iistorically0 the nited States has led the world in successfully defining contem%oraryenvironmental %rotection. hese environmental gains have -een achieved at great cost throughheated legal and %olicy de-ates characteristic of the .S. environmental movement. So far0 thiscom%lex and im%erfect assem-ly of commandDandDcontrol re@uirements has contended well withnumerous diverse forms of %ollution inherent to a dilating economy. 'ramatic turns in theeconomy0 however0 and unforeseen changes in manufacturing suggest that more ada%tive0

    %erformanceD-ased environmental management methods are needed.

    &n the nited States0 as elsewhere0 environmental %rotection must increasingly rely oninnovations in environmental management if a more advanced environmental managementframework is to emerge early in the ("st century. he %olicy dialogue in the nited States viewsEMSs as an im%ortant emerging tool that hold %otential for linking -usiness logic withenvironmental goals and res%onsi-le stewardshi% for actual environmental im%rovements-eyond what the %resent configuration now offers. As the PresidentBs ouncil on Sustaina-le'evelo%ment >PS'? said0 /allone0 environmental management systems >including B%ro%erlycertified &S) "*++" systems? do not necessarily ensure im%roved environmental %rotection and%erformance. $ather0 effective EMSs can %rovide significant structural su%%ort for im%roving%erformance if cou%led with @ualitative and @uantitative %erformance commitments and goals>PS' "0 %. *J?

    Environmental anagement Systems in the United States

    A diverse grou% of organiCations0 associations0 %rivate cor%orations and governments have -eendevelo%ing and im%lementing various EMS frameworks in the nited States and other %arts ofthe world for the %ast (+D3+ years. Hor exam%le0 the hemical Manufacturers Associationcreated its own framework called

    $es%onsi-le are in 19! &n addition0 the Hrench0 &rish0 'utch and S%anish governmentsdevelo%ed their own voluntary EMS standards in the 190s and 1990s, and %erha%s moreim%ortant was the develo%ment of =S 775+ in the nited !ingdom0 the founding document of&S) "*++". >See discussion in ! section a-ove.?

    Pro-a-ly the most telling develo%ment surrounding the use of EMSs is the ado%tion and

    %roliferation of the &nternational )rganiCation for StandardiCation >&S)? EnvironmentalManagement Standard0 the &S) "*++" EMS standard0 finaliCed in Se%tem-er "6. $evisionshave now -een %ro%osed0 -ut the intent of this standard is to %roduce a single framework forEMSs0 which can accommodate varied a%%lications all over the world.

    &n the nited States0 &S) "*++" im%lementation and certification was slow to take off during thefirst two years0 as a num-er com%anies took a wait and see a%%roach to the standard. his wasdue to a num-er of reasons0 which included mixed regulatory signals from the EPA and stateenforcement -odies0 as well as limited outreach efforts -y the American -odies res%onsi-le for

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    the develo%ment of the &S) "*+++ seriesDthe American 1ational Standards &nstitute and the .S.echnical Advisory 2rou% to echnical ommittee (+7. &n Se%tem-er "70 one year after thefinal %u-lication of &S) "*++"0 only 3* com%anies had received thirdD%arty certification to thestandard. hose com%anies were mostly from the chemical and electronics sectors. >thosesectors continue to lead in certification num-ers today.?

    =ut -y He-ruary "J0 &S) "*++" certification num-ers in the nited States -egan to increasesignificantly0 with larger com%anies such as the &=M or%.0 Hord Motor o. and Gockheed Martincertifying to the standard with great vigor0 and total certification num-ers nearing "++. hat yearalso ex%erienced increased activity within the .S. Envir9Jnmental Protection Agency0 whichlaunched several EMS initiatives and released a %osition statement on the %u-lic %olicyim%lications of &S) "*++" and EMS im%lementation in the nited States.

    he %rivate sector -egan to react %ositively as well to EMS -enefits following the EPA %ositionstatement. Soon after0 &=M announced that it would strongly encourage its hundreds of su%%liersworldwide to im%lement an &S) "*++" system0 8ust short of a re@uirement of doing -usiness./ust a few months later0 the Oerox or%. issued a similar re@uest to it 3+0+++ su%%liers aroundthe world.

    he stage was then set for argua-ly the -iggest develo%ment to date in the nited States

    concerning &S) "*++". &n Se%tem-er "0 he Hord Motor o.0 after certifying more than "*+of its own manufacturing sites glo-ally and %roclaiming the millions of dollars it saved in wasteminimiCation and other environmental initiatives0 announced that it would re@uire &S) "*++"certification of its su%%liers -y (++3. he 2eneral Motors or%.0 @uickly reacted in the daysfollowing the Hord announcement with its own &S) "*++" re@uirement of its thousands ofsu%%liers. his single event will likely sha%e the EMS market for the next decade0 as thousandsof com%anies will -e affected -y the automotive mandate. At the end of "0 certification totalsto &S) "*++" in the nited States reached a remarka-le 6++0 and are ranked 7th highestheading into (+++.

    Moreover0 the end of " saw more EMS initiatives from the %u-lic sector0 and continued togain ground as a %olicy tool. he linton administration issued an executive order in late "that re@uiring all federal agencies to -egin environmental management system %ilot %ro8ects -yMarch 3"0 (++(0 and to esta-lish an effective EMS at all federal facilities -y (++5. he federalmandate will directly affect all "6 de%artments in the Executive -ranchDwhich includes more than"50+++ federal facilities0 %lus other agencies as well0 such as the ennessee ,alley Authority0 the2overnment Printing )ffice and the .S. Postal Service. he draft order0 tentatively titled2reening the 2overnment hrough Geadershi% in Environmental Management#B will re@uire asystem -ased on the .S. Environmental Protection AgencyBs ode of EnvironmentalManagement Princi%les >EMP? or other a%%ro%riate existing EMS standards0 such as &S)"*++".

    )ther significant %olicy initiatives em-racing the EMS framework include reinvention activities atEPA0 and the final re%ort of the S PresidentBs ouncil on Sustaina-le 'evelo%ment in May". EPA also issued two re%orts concerning EMSs# he first was in August " and titled0Aiming for Excellence# Actions to Encourage Stewardshi% and Accelerate EnvironmentalProgress he re%ort included a strong commitment to utiliCing environmental management

    systems a%%roaches0 the first such clearly %roactive statement on EMS from EPA0 and a furtheragency commitment to develo% a %erformance track or alternate regulatory %athway. Such aninitiative will likely rely heavily on EMS im%lementation and third %arty certification.

    he second EPA re%ort came in 'ecem-er " in a draft form0 which will -e the agencyBsAction Plan for E&,&Ss. his new %lan is the most com%rehensive %olicy a%%roach concerning&S) "*++" to date in the nited States0 and will likely garner significant discussion and de-ate inthe early months of (+++. >See attachment.?

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    Testing the ES Ground

    esting the environmental management %erformance of E&,&Ss is now a central feature of mostreform initiatives in the .S. regulatory scheme. Hor instance0 the MultiDState ;orking 2rou%>MS;2?0 now re%resenting nearly all of the states0 has entered a %ilot research %rogram with.S. EPA and niversity of 1orth arolina s%ecifically to test and measure how EMSs mayachieve -etter environmental %erformance.

    he .S. Environmental Protection AgencyBs Pro8ect OG0 the Environmental Geadershi%Program0 and the Star rack %rogram all recogniCe and rely on the voluntary use of effectiveEMSs in one way or another as %art of a overall %rogram of com%liance assurance. Similarly0several states including onnecticut0 Hlorida0 Massachusetts0 1ew /ersey0 )regon and;isconsin have created alternative or su%%lementary regulatory %rograms >See A%%endix A? thatoffer various administrative incentives for %artici%ating com%anies. Most state and federalincentiveD-ased or voluntary %rograms re@uire a %artici%ating com%any to have an EMS in %lacein addition to other features0 such as a good com%liance record0 a ro-ust environmental %olicy0some form of auditing either internally or -y a third %arty and a commitment to continuousim%rovement and -etter environmental results.

    &n exchange0 the government %rograms usually offer incentives such as oneDsto% sho%%ing

    >consolidating %ermit and regulatory activities for greater convenience and efficiency? someform of audit %olicy to allow a com%any time enough to identify and correct %ro-lems detected -ythe EMS or audit >not to -e confused with state audit %olicies that shield com%anies fromlia-ility or offer them immunity#B which is a @uestiona-le %olicy issue? and ex%edited %rocessingor more flexi-ility for %ermits. Most voluntary or incentive %rograms are focused on com%liancewith existing laws0 however0 and use regulations as the measure of environmental %erformance.

    Third,+arty Certi"i'ation and -uditing S'hemes

    he evolution of EMSs directly %arallels the emergence of more accurate auditing methods andregistered certification %ractices. Gooking forward to more %erformanceDfocused systems ofenvironmental management and com%liance0 the goal for %u-lic oversight is to model newenvironmental %rograms to encourage higher levels of %erformance. o do this0 modernenvironmental regulatory %rograms will want to enlist only com%anies with com%rehensiveEMSs0 whose %erformance is audited and whose EMSs are certified -y accredited third %arties.he current scheme in the nited States was esta-lished -y a 8oint agreement -etween the

    American 1ational Standards &nstitute >A1S&? and the $egistrar Accreditation =oard in "70formally called the 1ational Accreditation Program0 which accredits all as%ects of the thirdD%arty%rocessDEMS training courses0 EMS auditors and EMS registrars.

    he incentive for a com%any0 for exam%le0 is the o%%ortunity to concentrate all of its annualregulatory and re%orting -urden into a single eventDan annual thirdD%arty certification of thecom%anyBs conformance with a com%rehensive EMS that measures and re%orts com%liance and%erformance results. his strategy0 which many reform %rograms in the nited States areconsidering0 entails the use of EMSs0 consolidated or unified re%orting and the growing field ofregistered thirdD%arty auditing and certifying services to verify ongoing or continual conformitywith the s%ecified EMS in %lace and o%erating.

    =ecause of much confusion and concern among -usinesses0 environmentalists and somegovernment officials over the use of EMSs0 it is very im%ortant to distinguish -etween the %rivatesector use of EMSs0 which only measure a com%anyBs %erformance against what it says it wantsto measure >which is all that &S) "*++" is su%%osed to do0 although standardiCed?0 and the useof EMSs in a alternative regulatory strategies that setDu% criteria for demonstrating0 auditing andcertifying com%liance and other critical information on actual environmental %erformance>sometimes referred to as an EMSD%lus system?.

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    )ne im%ortant attri-ute for environmental %rotection and oversight agencies to consider is thedevelo%ment of an effective and ada%tive environmental audit %olicy. Audit %olicies musts%ecify0 regardless of the ty%e or sco%e of any %articular EMS0 under what conditions a com%anywill -e eligi-le to %artici%ate in voluntary %rograms or initiatives0 and under what conditions theagency will reduce0 toll or modify %enalties in exchange for an eligi-le com%any having ademonstra-le system in %lace for meeting0 verifying and re%orting environmental %erformanceoutcomes.

    Garger facilities and firms are es%ecially likely to want -enefits from a regulatory relationshi% withan oversight agency ca%italiCing on the environmental %erformance and managementinformation -eing generated from the com%anyBs use of EMSs. =ut for this to occur0 mostex%erts -elieve that accredited thirdD%arty firms should verify the regulatory as%ects ofenvironmental management0 com%liance and %erformance. )ther nonDregulatory as%ects of acom%anyBs environmental management that are not re@uired -y law could -e selfDcertified.Iowever third %arty verification and attestation would increase the %u-lic re%orting value. &neither case0 third %arty certification to verify critical %u-lic information and results will -uildgreater %u-lic confidence than selfDauditing and certification. ogether0 these tools %rovide amanagement techni@ue for demonstrating im%roved %erformance0 which is something mostcurrent regulatory systems do not do.

    #n"ormation anagement

    &n any system for managing and %rotecting human health and the environment0 whether it is a%erformanceDfocused system utiliCing EMSs or the traditional regulatory system0 %erformance-aselines >i.e.0 -enchmarks? need to -e esta-lished for facilities0 firms and sectors. $egardlessof the difference -etween firms and sectors0 the information collection or retrieval system should-e set u% in a crossDsectional way so that each %iece of information %erforms multi%le 8o-s#

    Provides environmental %erformance -aseline or -enchmarks re%orting information >e.g.0energy efficiency0 water usage0 discharge0 releases0 toxins usage0 resource %roductivity0 etc.on 3D* levels >facility0 firm0 sector?

    ollects information that satisfies regulatory re@uirements -ut also shows com%lianceassurance and environmental %erformance results

    Monitors0 calculates or tracks am-ient environmental conditions $ightDoD!now informationfor communities >i.e.0 accounta-ility? and

    &m%rovement or %rogress >this information is useful to the government0 financial community0and the %u-lic?.

    his kind of information -ase is already -eing constructed -y EPA in coo%eration with theMS;2 in an EMS re%orting %rocess that feeds into EPAs enter Environmental &nformationand Statistics.

    A set of common environmental %erformance0 management and com%liance metrics also needto -e advanced in order to im%lement %erformanceDfocused use of EMSs. Several

    multiDstakeholder grou%s have recommended what these set of re%orting indicators ought toinclude >e.g.0 Environmental 'efense HundBs scorecard0 2lo-al $e%orting &nitiative >2$&?0ommon Sense &nitiativeElectronicsB $E0 Environmental Geadershi% Program0 Star rack0$es%onsi-le are0 and the MultiDState ;orking 2rou% >MS;2?. here is agreement enough onthese core information elements to get started >most are known and can -e gleaned from a halfdoCen initiatives that have already -egun to answer this @uestion?.

    he coDgenesis of information management technology0 as well as consolidated0 electronic andoneDsto% re%orting0 are all necessary to fully understanding and utiliCing EMS methodology.

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    )ne of the challenges to moving o%erating com%anies and the regulatory agencies into%erformanceDfocused management %rograms is to develo% information management andadministrative mechanisms that com%lement the use of EMSs.

    &n the nited States0 various efforts are underway to consolidate re%orting re@uirements0 offeroneDsto% re%orting or %ermitting registration0 and to convert to electronic re%orting. Each of thesecostDeffective activities is currently -eing %ursued -y EPA and some states. he resourcesavings to -oth the regulated community and government suggest that this form of informationre%orting >e.g.0 consolidated and electronic? will shortly -ecome the norm.

    =ut consolidated and oneDsto% ty%e re%orting >i.e.0 %ermitting0 registration0 renewals0 etc.? arenot yet fully a%%lica-le on a wide scale. !ey facility identifiers -egin to tie the various statutoryand regulatory re@uirements of a facility into a single %oint of reference0 -ut the nited Stateshas not as yet offered the a-ility to consolidate all regulatory and administrative re@uirementsinto a single re%orting and registration event for any of the ma8or o%erating sectors. he furtherdevelo%ment of this ca%acity does not cause a %erformanceD-ased system to fully materialiCe0-ut it is a critical efficiency ste% and could -e %art of how to organiCe under a sector a%%roachsu%%orted -y certified EMSs.

    .inan'ial #ndustry -nalysis

    Most financial analysts from insurance0 e@uity or lending institutions will tell investors that it isnot the kind of environmental management system that matters. &t is what the com%any has saidit was going to do in the EMS0 and whether or not the com%any %roved to do what it said it wasgoing to do. &f a com%any didnBt say that it was going to do much0 and it shows that it didnBt domuch0 then that is the story0 regardless of the needs of the environment. Hor exam%le0 acom%any without an EMS could %otentially score much higher in the overall financial analysisde%ending on how well the com%any is %erforming against what it said it would do. he com%anyhas to set to some goals and o-8ectives and it has either met them or not.

    he financial analyst may not agree with those o-8ectives or goals0 -ut they see that the %olicyand a %rocess are in %lace. ;hat the analyst wants is to go to the com%any or anotherinformation source to determine what the com%any views as its environmental managementres%onsi-ilities0 and then determine how well the com%any manages itself accordingly or not.'e%ending on the industry0 lending for instance0 the analyst may try and guide a com%any intoan area where0 in his view%oint0 will reduce risk.

    &n another exam%le0 an insurance com%any will go into a com%any and see that it has had somehistorical losses. hat doesnBt mean -ecause a com%any may have had loses that the com%anycannot -e insured. ;hat most analysts are looking for is that a com%any will likely detect andcorrect %ro-lems as they arise0 and that the organiCation has a framework in %lace0 such as anEMS0 to do this effectively and consistently.

    According to what the analyst identifies and calculates0 the %rice of stock or credit may vary. &fan analyst assumes0 -ased on the environmental %erformance information he or she receives0that there was a thirdD%arty verification0 and that analyst is comforta-le with that information andwhat it shows0 so too will other -uyers and sellers or lenders. Aside from the information that an

    environmental management system would collect0 and regardless of all the %articulariCedenvironmental attri-utes and s%ecific as%ects that are sti%ulated -y the com%any0 the use andcom%lexity of the EMS reveal com%any -ehavior. he fact a com%any may or may not have anEMS is showing some ty%e of -ehavior and commitment0 whether or not this information isverifia-le or certified. Potentially0 a thirdD%arty audit or certification of the EMS and theinformation it %roduces will add another level of certainty to this analysis.

    Much of the analystBs or lenderBs 8o- is to determine whether or not to assume that the com%anyBsmanagement is committed and should -e extend credit resources. &f a lender sees0 in fact0 a

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    com%any is dedicated and it has -uilt in and integrated into the %rocess means for reducing riskand lessening im%acts0 it will -e much more comforta-le that that this level of -ehavior willcontinue0 -ecause there is money -eing set aside for it.

    ntil recently0 much of this section on the linkage -etween EMS and Hinancial Analysis mayhave -een somewhat s%eculative. Iowever0 with the advent of such initiatives as the 'ow /onesSustaina-ility &ndex and a similar rating %rogram from &novest0 it is likely that this methodologywill see ra%id acce%tance within the ;all Street community.

    -lternative (egulatory +rograms/ Generi' .rameor*

    his outline of a generic alternative regulatory %rogram is synthesiCed from %ro%osed andexisting %rograms develo%ed over the %ast 5 or more years. Exam%les include the As%en&nstitute0 Enter%rise for Environment0 S EPA ommon Senses &nitiative0 EnvironmentalGeadershi% Program0 Star rack and Pro8ect OG recommendations.

    he conce%t of an alternative regulatory %rogram >e.g.0 alternative or innovative regulatorystrategies0 %athways0 etc.? is increasingly recogniCed as a %otential regulatory transition tool -yvarious interests from -usiness0 government and the environmental community. 1early all such%rograms rely on the im%lementation or existence of varying forms of Environmental

    Management Systems >EMSs?. $easons cited for im%lementing or authoriCing such a %rograminclude the following#

    $esources are increasingly constrained0 making it im%erative to identify ways of achievingenvironmental goals more effectively and more efficiently.

    Environmental managers at com%anies in %artnershi% with an active grou% of community orenvironmental stakeholders are sometimes well %ositioned to ex%eriment and decide whata%%roaches will yield -etter environmental results than can -e achieved under existing orforeseea-le regulations.

    ;ith %ro%er safeguards0 allowing flexi-ility can su-stantially reduce com%liance costs andmake industries more com%etitive0 %rovide for much greater community involvement in thedecisions of their neigh-oring industrial %lants0 foster coo%erative %artnershi%s andencourage greater innovation and -etter results in meeting environmental goals.

    oo%erative com%liance strategies utiliCing EMSs and that -undle small D or mediumDsiCedenter%rises together as units under an alternative com%liance %ro%osal0 or agencies acting in%u-lic%rivate %artnershi%s as a%%licants with multi%le entities0 can achieve outcomes withsignificantly greater environmental com%liance rates for entire industry sectors or regions.

    here are two -asic models of an alternative regulatory %rograms for EnvironmentalManagement Systems#

    a. Pilot %rograms to test out new ideasa%%roaches with EMSs for -roader reform of genericenvironmental management %rograms%rocesses >i.e.0 general system lessons -etter facility-ased management?.

    -. A variance or alternative regulatory %rogram that %romotes environmental %erformance andim%rovements -y offering %artici%ating entities flexi-ility for meeting environmental%erformance goals through contractual commitments -ased on EMS and %erformancecriteria rather than under the commandDandDcontrol re@uirements alone.

    hese conce%ts are not mutually exclusive. &n -oth cases0 however0 an array of minimalre@uirements0 safeguards and authority are necessary for %roviding a foundation that allows%artici%ating com%anies to transition from a com%lianceD-ased management a%%roach to a%erformanceD-ased a%%roach that utiliCes EMSs0 auditing0 %u-lic re%orting and certification.

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    he general %ur%oses for an alternative regulatory %rogram are -ased on the need to antici%atethe future of our environmental management framework. o do this0 %rograms designed toauthoriCe trial ad8ustments to existing environmental regulatory re@uirements calculated tomeasura-ly im%rove environmental results are emerging at -oth the state and federal level ofgovernment. hese %rograms su%%lement an agencyBs current ca%acity to overseeenvironmental %rotection -ut allow greater variance with existing legal re@uirements undercertain conditions. Such %rograms also %rovide regulatory lessons and information a-out thetransition to a future environmental management. Alternative regulatory %rograms com-ineexam%les of economic efficiency0 environmental management systems and %ollution %reventionthat em%hasiCe -etter environmental results under systematic controls designed to informchanges to the existing management framework.

    Most state and federal alternative regulatory %rograms re@uire some form of EMS0 -ut also go onto re@uire %erformanceDoriented commitments. Hor instance0 %rograms tend to feature#

    a. hat the a%%licantBs %ro8ect in total must %rovide documented antici%ation of su%eriorenvironmental %erformance >SEP? or -etter environmental results and

    i. he %ro%ortionality of the -etter environmental result to the degree of flexi -ility

    sought should -e considered or weighed -y im%lementing agency. A %ro%ortional-alance should also -e sought -etween the level accounta-ility and themodifications sought

    ii. Some nexus should exist -etween the environmental result-enefit and theregulatory modifications sought although a -alance of environmental im%rovements>e.g.0 %ollution %revention? could -e identified through the stakeholder %rocess

    iii. Pro8ects that seek overall reductions in releases should not result in any significantincrease in existing releases that adversely affect individuals0 any %o%ulation ornatural resource. Pro8ects cannot shift or trans%ort %ollutants that %ose significantrisks of adverse effects from one %o%ulation to another su-8ect any %erson or%o%ulation to un8ustDor dis%ro%ortionate environmental im%acts and cannot result inany significant increase in the risks of adverse effects to the health of individuals0any %o%ulation or natural resources.

    -. Am-ient health and environmental @uality standards would -e maintained. Exigentcircumstances such as nonDattainment status will -e assessed accordingly to %reserveex%ected regional or mediaDs%ecific goals.

    c. Pro8ects that achieve only administrative relief andor cost savings are a%%rova-le if someof the savings are a%%lied toward environmental -enefit. 1o s%ecific definition or thresholdof environmental -enefit would -e defined -ut would -e left to the stakeholder %rocesssu-8ect to a%%roval authority. 'iscerni-le %erformance -aselines0 %ro%ortionality and nexusshould -e demonstrated0 however >see >a? a-ove?.

    d. SA!EI)G'E$ P$)ESS# A stakeholder %rocess meeting the following minimum criteria

    are usually created for individual %ro8ects#

    Hull %u-lic disclosure of information and o%en access to stakeholder %roceedings or%rocesses >trans%arency?.

    Provides for the develo%ment and dissemination of information ade@uate to ena-leverification of environmental %erformance -y any interested %ersons. onsensusD-aseddecision making >normally advisory although %ro8ects could include other decisional

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    rules0 -ut no individual vetoes?0 s%ecific rules and codes of conduct to -e decided -ythe stakeholder team >a selfD%olicing system in most %rocesses?.

    =alanced stakeholder grou%s re%resentative of all interests.

    Ensures that ade@uate technical su%%ort or resources exist for an effective %rocess.

    Stakeholder %rocess could -e amended or waived under certain circumstancescontingent on a%%roval authority if there is insufficient interest in convening stakeholder%artici%ants. And

    he stakeholder %rocess would not -e useful in view of the routine or nonDcontroversialnature of the %ro%osal.

    he recommendation of a -road consensus of the stakeholder grou% is weighed heavily in thea%%roval decision.

    f. A%%roval would -e -ased on =)I the su-stance of the %ro8ect agreement as well as theim%lementation of the stakeholder %rocess >the %rocess would have to -e documented %riorto a%%roval?.

    g. riteria for determining SEP or a -etter environmental result should include -enchmarks fornew and existing facilities.

    h. he a%%roval authority should seek a diverse array of a%%lications -ased on such factors asfacility siCe0 %ro8ect sco%e0 %u-lic%rivate %artnershi% and %ollution %revention o%%ortunities0etc.

    A%%roved %ro8ects must record and re%ort information sufficient for the agency to measure andevaluate the merits and -enefits ex%ected to -e achieved.

    i. Each a%%roved %ro8ect would -e evaluated in the context of the overall alternative regulatory%rogram in order to assess generic changes to the management system0 recommendchanges in re@uirements and ultimately re%ort to ongress.

    8. Methodology# A %u-lic %rocess re%resentative of all stakeholder interests should -eem%loyed -y the agency to aid in its overall evaluation of the %rogram.

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    ISO ,-..,+ A VIABLE PUBLIC POLICY TOOL TO ACHIEVE SUSTAINABILITY IN/APAN

    /a%an leads the world -y a wide margin in terms of the num-er of com%anies certified to the &S)"*++" international environmental management systems standard0 nearing the 30+++ mark as of/anuary (+++. =ecause of this tremendous u%take of the standard0 /a%an was chosen as a

    fundamental case study to understand the various %arameters driving the %rocess of &S) "*++"im%lementation and %olicy making.

    Since the -eginning0 /a%an has taken a integral role with &S) "*++"Bs develo%ment to %rovide aflexi-le framework for incor%orating and integrating environmental management into the core-usiness decisionDmaking %rocess of /a%anese industry. &t is widely -elieved in /a%an >andelsewhere? that the %ro%er im%lementation of an EMS will im%rove internal organiCationalefficiency0 %rovide com%etitive advantage and enhance %u-lic image0 which may o%en the doorfor regulatory flexi-ility from governmental -odies as well as %referential financial treatment -yinsurance and lending institutions.

    Additionally0 many ex%erts are convinced that the &S) EMS standard will also facilitateinternational trade0 something vital to /a%anese industry0 which im%orts more than J+ %ercent ofits natural resources to %roduce one of the worldBs strongest economies. his review of the

    /a%anese ex%erience is to understand the nature of forces %ushing the im%lementation of &S)"*++" in /a%an0 the economic and environmental -enefits of its im%lementation and thefeasi-ility of transfera-ility of this %rocess to other countries to develo% a working %u-lic %olicymodel for encouraging &S) "*++" im%lementation for sustaina-ility in other countries.

    "SO 1#001 "m$%&mentation in 'a$anAs mentioned -efore0 /a%an is the world leader in ado%ting&S) "*++". he country -oasts nearly 30+++ registered com%anies0 according to recent figuresfrom the /a%an Accreditation =oard for onformity Assessment >/A=?. hat figure re%resentsnearly a @uarter of the worldwide total0 followed -y 2ermany with an estimated "05++certifications and the nited !ingdom with "0+++. Earlier surveys have consistently identified/a%an as the world leader0 followed -y 2ermany0 and the nited !ingdom0 Sweden and aiwan.he trend is likely to continue and according to some forecasts0 the num-er of registeredorganiCations will dou-le in the next three years.

    he myriad organiCations that have achieved &S) "*++" registration in /a%an are also worthnoting. he remarka-le variety of /a%anese organiCations0 from -oth the %rivate and %u-licsectors0 ranges from factories to government offices to su%ermarkets and also varies in siCes. Asin most other countries0 the manufacturing industry such as electrical machinery and e@ui%ment0chemical0 trans%ortation e@ui%ment0 organic %roducers0 farmers0 and wholesalers0 %aint andcoating industries0 accounts for the significant %ro%ortion of &S) "*++" registration. he list ofregistered nonDmanufacturing organiCations includes schools0 universities0 -anks0 trading housesand even su%ermarkets. 2overnment agencies are also esta-lishing and registering for EMSs.he /a%anese Environment Agency0 for exam%le0 is seeking registration0 as are an estimated J+local governments. More than a doCen local government entities are already registered to thestandard.

    'es%ite the high num-er of certifications in /a%an0 the reasons for im%lementing &S) "*++" are

    much the same in this country as they are in the rest of the world. om%anies see an EMS as ameans of im%roving their environmental %erformance and %u-lic image0 reducing costs -yconserving energy and resources0 motivating em%loyees0 distinguishing themselves from thecom%etition and ex%anding their %ool of %otential clients.

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    The #S$ 1000 (ea'tion

    )ne of the ma8or factors for such elevated certification efforts in /a%an is %erha%s theconse@uence /a%anese industry ex%erienced when the &S) +++ series was launchedinternationally for @uality assurance in the late "J+s0 according to )1SE1SS magaCine.

    Although those @uality standards are not -inding in terms of legal im%lications0 they @uickly-ecame the international norm in the early "+s0 and Euro%ean and 1orth American clientsinsisted that their im%orts fulfill &S) +++ re@uirements0 %articularly in the automotive sector./a%anese com%anies were slow to ado%t &S) +++ -ecause of their confidence in their own@uality control systems0 thus0 %utting them -ehind many of their com%etitors in the glo-almarket%lace.

    =ut /a%anese industry and the Ministry of &nternational rade and &ndustry >M&&? learned @uicklyfrom the costly lesson0 and when &S) "*+++ develo%ment -egan0 /a%anese firms did not want toex%erience a similar fate. Ience0 the /a%anese industry res%onded to the environmentalmanagement standards >&S) "*++"? right from the -eginning. 'uring the international EMS &S)"*+++ standards develo%ment0 the government and the industries with technology andman%ower0 took the initiative in sha%ing /a%anBs res%onse. /a%anese industries took %art in the%rocess through s%ecial task forces set u% in the /a%an Hederation of Economic )rganiCations>!eidanren? and other industrial -odies. his is true of -oth the esta-lishment of %rocedural and

    organiCational systems >esta-lishment of the accreditation and registrationcertification -odies0auditors training -odies? and %re%arations -y com%anies.

    &ndeed0 -ecause of this %roactive effort0 /a%an was one of the first countries to fully em-race theEMS standards0 and M&&Bs su%%ort and %ush was one of the crucial elements. According to Mr.Nano0 de%uty director of the Standards Planning )ffice within M&&0 the country ado%ted &S)"*++" s%ecification0 &S) "*++* guidance and &S) auditing standards in "6 to coincide withthe &S) timeline0 which also %rovided the infrastructure to esta-lish the certification andaccreditation scheme within the same time frame through the /a%anese Accreditation =oard. Anex%onential growth in the registration was o-served since the ado%tion of &S) as /&S. Accordingto /a%anese ex%erts0 many /a%anese com%anies were already im%lementing environmental%rograms that conformed to &S) "*++". hus0 com%anies such as Sony0 Ionda0 Ashaihemical0 &toh Nohkado Su%ermarket0 E-era or%oration and many utility com%anies got a headstart for im%lementation and the standardBs many -enefits to the -ottom line.

    Peo%le with extensive work ex%erience in Asia as well as with familiarity with /a%an -elieve anum-er of factors that are uni@uely /a%anese may also have %layed a role in the &S)im%lementation. !insella >,P of SS Engineers0 an international environmental consulting firm-ased in =ellevue0 ;ash.? -elieves that larger industries in /a%an are moving ahead undervoluntary suggestion with the /a%anese Ministry of &nternational rade and &ndustry. A growing%ercentage of /a%anese com%anies indicate that they will -e &S) "*++" com%liant0 if not certiDfied in the coming months. Additionally0 /a%an is an early leader in getting -eyond its own-orders0 with its ma8or com%anies even seeking &S) "*++" certification in overseas facilities0 in%laces like the nited States0 Asia and Euro%e.

    /a%anBs ma8or cor%orations are also on -oard0 setting good exam%les with EMS im%lementationand encouraging other firms to -ecome registered with guidance and a lessonsDlearned

    a%%roach. A list of registered com%anies %rovided -y &nternational Environmental Systems%date includes wellDknown names such as Sony >all manufacturing -ases are certified to &S)"*++". all nonDmanufacturing -ases must o-tain certification -y March (++"?0 Iitachi0 oshi-a0Sanyo >All the manufacturing sites worldwide0 including "* sites in hina0 aiwan0 !orea0 andfive sites in Southeast Asia have o-tained certification. Sanyo aims to have allnonDmanufacturing facilities certified -y A%ril (+++. or%orate Environmental Management in

    Asia Electronic Sector He- ?0 Hu8itsu0 Shar%0 anon and 1E >All overseas manufacturingsu-sidiaries must o-tain certifications -y )cto-er (+++. 1E om%onents Phili%%ines andian8iin 1E Electronics and ommunications &ndustry o. Gtd. have o-tained certification.?.

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    Matsushita Electrical &ndustrial has announced that it is giving %riority to su%%liers who have anEMS0 andis even considering offering financial assistance to su%%liers who want to im%rovetheir environmental %erformance.

    Most of oyotaBs manufacturing facilities around the world are registered0 including %lants in1orth America. oyota was the first automaker to secure &S) "*++" registration to the fullstandard in the nited !ingdom and in /a%an. oyota also has issued a guideline for tier "su%%liers in /a%an recommending that they -ecome registered to &S) "*++" -y the end of (+++.Iowever no decisions have -een made regarding the 1orth American su%%liers. IondaBsautomotive %lants in )hio are all registered to &S) "*++" and the com%any also re@uires itsmain su%%liers to register -y the end of (+++. Ionda -elieves that it must -alance its customersBdesire for fun and %erformance with societyBs need for less %ollution and lower energyconsum%tion.

    Governmental #nitiatives and ar*et !rivers

    According to amami agakuchi0 a s%okeswoman for the /a%an Fuality Assurance )rganiCation0government %olicy on environmental matters is also driving registration in that country. Iowever0there is no clear evidence on its cause and effects0 agakuchi adds.

    he /a%anese government is relatively aggressive toward environmental matters. /a%aneseofficials %redict the &S) "*++" certification growth will remain steady in /a%an as firms follow thelead of -ig name com%anies like Ionda0 oyota and anon. )ther ex%erts -elieve Asiancountries are looking at &S) "*++" as a way to maintain access to international markets andgain com%etitive advantage.

    According to 'r. Mohammed Matou@ >1$'0 %ersonal communication? another ma8or driver-ehind im%lementation of large com%anies is the glo-al trade re@uirements and the enhanced%u-lic image. Pressure from the /a%anese Environmental Agency or the /a%anese Standard&nstitute did not %lay any role in certification0 Matou@ said. Ie also stressed that smallDmediumDsiCed enter%rises >SMEs? are not likely to get certified to &S) "*++" in the immediatefuture due to cost -arriers0 -ut many of them do %ractice environmental management of somekind.

    )ther officials at the /a%anese Environmental Agency saw &S) "*++" im%lementation as atotally voluntary initiative on the %art of %rivate sector0 with some %romotion of the standardsfrom the Ministry of &nternational rade and &ndustry >M&&? and officials from the &S) "*+++committee. his outreach effort0 however0 %roved to -e significant to hel% disseminate theinformation a-out the standards0 to im%rove environmental %erformance0 to move towardsustaina-ility and to enhance %u-lic image -y %roviding im%roved environmental %erformancere%orts.

    /a%anese officials say that the electric a%%lianceconsumer electronics industry is res%onsi-le forthe ma8ority of certifications in /a%an0 with *+ %ercent of the market0 followed -y the chemicaland trans%ortation sectors0 adding u% to a cumulative sum of nearly (+ %ercent. his data is%arallel to other &S) "*++" certification markets in the nited States and the nited !ingdom.>See sections a-ove.?

    $ther ar*et !rivers

    =ecause the /a%anese economy is an ex%ort oriented country and so reliant on trade with othernations to take %art in the glo-al economy0 the new EMS standards were @uickly acce%ted as-usiness re@uirements. According to one estimate0 -y the time the final version of &S) "*++"was %u-lished in Se%tem-er "60 a-out twoDthirds of the countryBs electrical e@ui%ment industryhad already registered to the new standard.

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    =ut /a%anBs demogra%hy may also -e %laying a role in ado%tion of &S) "*++". As a small islandnation with limited natural resources0 /a%an im%orts most of the raw materials and energy ituses. /a%anBs land area is almost e@ual to that of alifornia -ut -ecause of the mountainousterrain0 only "*K of the land is ha-ita-le. Moreover /a%anBs %o%ulation is a-out half of the nitedStates0 whereas the .S. has 3+ times more land area than /a%an0 thus0 making /a%an a densely%o%ulated nation much like the 1etherlands. )ne sees %arallels in the way the two countries are%ursuing glo-al as well as local environmental issues. /a%an is realiCing the im%ortance ofenvironmental %reservation for the current and future generations.

    &n fact0 /a%anese interest in environmental issues is on the rise. 2lo-al warming0 climatechange0 resource conservation0 land use issues and %ollution are of serious concerns. 'uring thecountryBs ra%id growth in the "5+s and "6+s0 several highD%rofile incidents0 including over J+deaths due to mercury %oisoning0 led to wides%read concern a-out %ollution. he emergingglo-al environmental %ro-lems0 around the end of the "J+s0 made /a%an recogniCe the needsfor voluntary action toward good environmental management -eyond regulatory com%liance. &nthis co