Environmental managementsystems in the 21st century

By Ralph Stuart

The earliest focus of chemicalhealth and safety professionalswas on the risks to workers

from the hazardous chemicals theyuse. Whereas worker safety is still thedriving concern in most situations inwhich industrial hygienists and chem-ical hygiene officers are involved, thelast decades of the 20th centurybrought increased interest in the envi-ronmental effects of chemicals. Thischange has forced chemical healthand safety professionals to learn skillsin new technical areas, such as regu-latory relations and risk communica-tion. I expect this trend for a demandfor a broader skill base to continueinto the 21st century. Of particular in-terest will be the specific managementskills required to understand and im-plement an environmental manage-ment system (EMS) within an organi-zation. This article will describe thehistorical, political, technical, andbusiness reasons for this emergingneed and give some projections abouthow it will affect chemical health andsafety professionals.

ENVIRONMENTAL REGULATION INTHE 20TH CENTURYThe modern American environmentalmovement received official recogni-tion in the early 1970s with the found-ing of the Environmental ProtectionAgency (EPA) and the passage of aseries of laws (notably the Clean AirAct and the Clean Water Act) aimed atcontrolling the most egregious formsof pollution found at the “end of the

pipe.” However, as that decade con-tinued, it became evident that im-portant pollution sources besidesthere were the belching smoke stacksand open sewer pipes that were thetargets of those acts. Discoveries ofproblems at Love Canal and disasterssuch as that at Bhopal, India resultedin a new set of laws in the UnitedStates. These laws included Compre-hensive Environmental Response,Compensation and Liability Act(CERCLA), which established the Su-perfund for cleanup of chemically pol-luted dump sites, and Resource Con-servation and Recovery Act (RCRA),which established a hazardous wastetracking system to prevent the needfor cleanup of such sites in the future.

The regulations promulgated underthese laws were detailed and perspec-tive in their approach to managing theproblem at hand. For example,RCRA’s approach to hazardous wastedisposal requires that eight copies ofthe shipping manifests be made andtransferred between the parties in-volved and the government. This at-tention to detail enabled the regula-tors to have a significant impact on theproblem of concern.

The ambition of these regulationswas to manage hazards from cradle tograve, although the cradle did not in-clude the manufacture or sale of haz-ardous chemicals; regulation startedafter they were used. However, evenwith this restriction, the impact of theregulations came at a high cost anddid not result in less waste generated.In the case of the Superfund, it is com-monly estimated that the regulatorysystem for site cleanups resulted inover 50% of the money involved inthe cleanup efforts to be spent in ne-gotiating the terms of the cleanup,rather than remediation efforts.

Furthermore, even after these pro-grams were fully implemented, im-

proving science and technology wereable to detect continuing degradationof the environment. These newly rec-ognized problems (such as depletionof the ozone layer and global climatechange) are more complex to managethan those issues tackled in the firsttwo rounds of environmental legisla-tion because their sources and effectsare more diffuse. This developmenthas led environmental policy makers,such as government regulators, healthand safety managers, and leaders ofbusiness and industry to recognizethat a more holistic approach isneeded for managing the environmen-tal impact of the economy and specificorganizations within it.

Moving Up the PipelineAs a result of its interest in getting atthe source of the problem, the EPAhas specifically included the goals ofminimizing waste production and pre-venting pollution at its source amongits expectations for the regulated com-munity. This approach to environ-mental issues requires that organiza-tions go beyond compliance withcurrent regulations to strive for con-tinuous improvement of the manage-ment of an organization’s overall en-vironmental impacts.

This trend has led to significant in-terest in understanding and develop-ing EMSs in the 1990s. The Interna-tional Standards Organization (ISO)promulgated its standard for EMSs(ISO 14001) in 1996. Similar criteriafor EMSs have been developed by reg-ulatory agencies, including the EPA.

The EPA’s approach to an EMS issimilar to the ISO concept, but addsstronger weight to consideration ofregulatory compliance issues (not sur-prisingly) and transparency. “Trans-parency” means that the process of thedevelopment of the system and assess-ment of its results includes the govern-

Ralph Stuart is the EnvironmentalSafety Program Manager at theUniversity of Vermont and presidentof the Campus Consortium forEnvironmental Excellence.

231074-9098/00/$20.00 © Division of Chemical Health and Safety of the American Chemical SocietyPII S1074-9098(00)00146-5 Published by Elsevier Science Inc.

FEATURE

ment and the public as well as themanagement of the organization.These requirements are generally ap-plied only as part of an enforcementaction or to organizations seeking al-ternatives to the current system in reg-ulatory reinvention programs. How-ever, the political pressure for all usersof hazardous materials to considerEMS approaches is mounting rapidly.

WHY ARE ENVIRONMENTALMANAGEMENT SYSTEMSPOLITICALLY POPULAR?An EMS is an organized approach tomanaging the environmental effects ofan organization’s operations. TheEMS parallels other management sys-tems which help an organization ad-dress a particular issue that its leader-ship wants to emphasize (for example,there is a management system stan-dard for quality management estab-lished as ISO 9000). Managementsystems are described in a collectionof documents that follow a commonpattern: they are divided into policystatements, plans, procedures, andrecords, and the reasons for and rela-tionships between these documentsare explicitly recorded in the systemdocumentation.

The power of a management systemfrom the organization’s point of viewis that the structure and level of detailof a management system can be tai-lored to the needs and culture of aparticular organization. The manage-ment system usually can be built onexisting policies and procedures thathave been developed for regulatorycompliance purposes. However, asthese programs are brought together,overlap and duplication of effort areevident. The resulting EMS is usuallymore efficient to implement and easierto explain to the wide variety of audi-ences (workers, upper management,regulators, and the general public)who are interested in how it functions.

From the regulator’s point of viewthe importance of the managementsystem is that it provides a clear delin-eation of responsibility for the issuesthat regulations address. Many regula-tors believe that this significantly in-creases the likelihood that the organi-zation will comply with relevantregulations. The development and im-

plementation of the EMS make clearthat environmental protection is avalue important to the organization.

For policy makers, the attraction ofthe EMS approach is its focus on theidea of continuous improvement. Acomplete EMS includes defining spe-cific environmental indicators thatcan be tracked and regularly assessedto determine whether operationschange to become more environmen-tally friendly. Specific goals are alsoset to determine whether the system isdoing its job. This feedback loop isimplicit within the concept of an EMS,which is designed to allow changes tobe incorporated smoothly into the orga-nization’s operations. This means thateither upper management or the gov-ernment can modify environmentalgoals over time without disrupting workthat is already proceeding.

This idea of continuous improve-ment contrasts sharply with the exist-ing regulations mentioned previously,which assume that certain criteria canbe established for environmental prac-tices that will ensure that environmen-tal performance will always be opti-mal. Regulated organizations areexpected to meet those criteria imme-diately and pursue them indefinitely,whether they meet changing require-ments or not. RCRA regulations arean example of this type of regulation.Whereas its cradle to grave trackinghas been successful at preventing poordisposal practices for hazardouswastes, it has not been a significantspur to pollution prevention effortswhich would actually reduce theamount of hazardous waste produced.For this reason, many people in theEPA are interested in encouragingEMS development; they see the needto move beyond focusing on compli-ance toward stimulating good prac-tices, such as design for the environ-ment and pollution prevention, in asystematic and consistent manner.

WHY ARE EMSs EMERGING NOW?Besides the historical and politicalreasons described earlier, there are avariety of technical and business rea-sons why EMSs are becoming promi-nent in the early 21st century. Thesereasons include the development of

highly integrated information resourcesand networks in the 1990s and the re-organization of businesses that havetaken place as the information econ-omy developed over that decade.

Technical ReasonsAn EMS is an information-based ap-proach to managing the environmen-tal impacts of an organization’s activ-ity. It focuses on the relationshipbetween different kinds of work goingon in the organization. For example,the purview of an EMS may includehazardous waste procedures, waste-water treatment facilities, and disposaland management of air pollutionsources. Whereas these activities canbe operated independently of eachother, they have three common fac-tors. First, their results physically af-fect the environment shared with thegeneral public. Second, these are allof well-established interest to a varietyof federal, state, and local regulatoryagencies. Third, they are not likely toproduce a revenue stream for the or-ganization, and thus they competewith each other for the resources thatthe organization chooses to devote toenvironmental management.

Balancing the budgetary and policydemands of these programs requiresthat a large amount of data be col-lected and distilled into usable infor-mation. Until the development andproliferation of computers and com-puter networks, this data managementrequirement was a prodigious under-taking involving many different peo-ple and problems. However, the de-velopment of the Internet andassociated information technologieshas changed the nature of this prob-lem. The development of new infor-mation management tools and skillsfor using these resources have enabledmanagers to expand environmentalprograms based on data and informa-tion, rather than bureaucratic politicsand the latest new regulation. This is anecessary precondition to the devel-opment of an effective EMS.

Another technical trend that has re-inforced the effect of the revolution ininformation technology is that sci-ence and technology have gotten bet-ter at detecting and measuring traceamounts of environmental chemicals.

24 Chemical Health & Safety, November/December 2000

It is now routinely possible to measurewater and air contaminants at partsper billion levels. These data are easierto generate for a large number of sam-ples, thanks to the electronic instru-mentation and information manage-ment techniques. At the same time,there is increased scientific evidenceand appreciation for the subtle effectsof these contaminants on humanhealth and the ecosystem in general.

To be able to convert these newlyavailable data into usable informationthat informs good policy decisions,the health and safety professional hasto understand not only where the datacome from, but the expectations andneeds of the audiences who are askingfor access to these data. An EMS an-ticipates this question by establishinga system of environmental indicatorsand goals that provide a context fornew information. Whereas the valueof particular indicators and the ade-quacy of the goals are likely to be sub-ject to debate, establishing a contextfor that debate is a technical chorethat the EMS provides a tool for ac-complishing. This aspect is one reasonfor the resistance to reliance on EMSfor regulatory purposes; many envi-ronmental grassroots groups are reluc-tant to allow the technical debate tobe framed without explicit emphasison their concerns.

Business ReasonsAlthough the technical and politicalmotivations for developing EMSs arestrong, they are unlikely to be power-ful enough to spark a trend that affectsdaily operations as strongly as EMSsdo on their own. The current popular-ity of EMSs has developed becauseEMSs are useful from a managementpoint of view as well. There are severalspecific advantages to the EMS ap-proach for the internal operations ofan organization, particularly businessesoperating in the current economy.

The first economic trend that is im-portant to the emergence of EMS isthe increasing prominence of organi-zations and markets which cross lo-cal, state, and national boundaries.Because organizational developmentis not limited by political jurisdictions,businesses and institutions often findthemselves subject to a wide variety of

laws and regulations that address thesame issues in different ways. This cancreate confusion for management andworkers who are trying to understandhow to apply similar procedures at dif-ferent sites.

The EMS approach is an attempt tohead off this problem by establishingan internal company standard for en-vironmental management which willapply equally well in different jurisdic-tions. This is why there is a strongemphasis on going beyond compli-ance in the EMS literature: Regulatorycompliance is usually inadequate toachieve the state of the art practicewith regard to environmental manage-ment which is needed to satisfy themost demanding jurisdiction.

A second business trend of the1990s that reinforced the tendency to-ward EMS development was corpo-rate downsizing that eliminated alarge chunk of middle management inlarge corporations. The loss of institu-tional memory that this developmentcreated demonstrated the weakness ofan EMS that relied on regulatory im-peratives to set its agenda. The ISOmodel of an EMS places great emphasison documentation and coordination ofenvironmental programs to allow theseprograms to grow and shrink withoutdisrupting their mission as the resourcesavailable to them change.

A third event that has promoted de-velopment of EMSs is that events suchas the Valdez oil spill have focusedthe attention of upper management inlarge organizations on environmentalliabilities and their management. Thecombined financial and legal ramifica-tions of poor environmental perfor-mance have created pressure for cor-porations to understand how wellthey are doing in environmental af-fairs. People without day-to-day con-tact with the technical challenges ofwork in the field, such as upper man-agement, seek performance measuresthat can be used to summarize thevalue of the environmental programand the resources it consumes. Withoutan integrated management approachthat an EMS provides, developing suchmeasures is a daunting project.

In addition, the shrinking of middlemanagement noted earlier has re-sulted in outsourcing of many produc-

tion functions in the organization. Tomanage the risks associated with theloss of control outsourcing creates,managers have seized upon evalua-tion of their suppliers’ EMS as an im-portant tool. Some corporations re-quire that all the suppliers achieveISO 14001 certification before doingbusiness with them.

CONCLUSIONEnvironmental management systemsare quickly becoming popular. Thereare a variety of important reasons forthis. An EMS can be an effective toolfor communicating the value of an en-vironmental program to a wide varietyof audiences. For the chemical healthand safety professional this can be acritical advantage in obtaining the up-per management support necessary todo a job effectively.

However, there is a chicken and eggproblem in that an EMS cannot func-tion effectively without a commitmentfrom the upper management to itsgoals. Implementing an EMS is not asimple process because a completeEMS is likely to affect every aspect ofan organization’s operations. Supportfor the EMS does not simply requiremore resources. For example, the in-formation systems required to supportan EMS involve the organization’semployees, operations, purchases,and facilities. If any of these systemsare ineffective, they will limit the ef-fectiveness of the EMS.

Environmental management sys-tems will not cure environmentalproblems by themselves. They willplace new demands on the planning,management, and communicationskills of chemical health and safetyprofessionals. They will require syn-chronized development of other infor-mation systems within an organiza-tion. However, these developmentswill be in line with the needs of theincreasingly complex needs of largeorganizations in general. For example,chemical health and safety profession-als who are involved in occupationalhealth and safety issues will also findthat these skills and information sys-tems can equally valuable on thosefronts. For these reasons, I expectEMSs to be a prominent feature of the21st century.

25Chemical Health & Safety, November/December 2000