Performance on Environmental Management Systems

Performance on Environmental Management Systems: a Global View
Artigo publicado e apresentado no International Symposium on Technology Transfer IAWQ/ABES, 1995 –

Neste artigo são apresentados os principais resultados das discussões atuais sobre a performance ambiental. E são apontados os requisitos da BS 7750 e das Normas da EMAS relacionadas a este trabalho.

Existing standards of Environmental Management Systems (EMS) – BS 7750 and EMAS (The Eco Management and Audit
Scheme) – put strong emphasis on organizations environmental performance. Meanwhile, ISO TC 207 dedicates a specific
subcommittee, coordinated by the USA representative, to develop standards to environmental performance evaluation.
This fact is related to these standards objectives: to provide a system to ensure and demonstrate compliance with stated
policy, and ensure and demonstrate continual improvement of environmental performance. Furthermore it is important to
ensure credibility of the environmental certification and accreditation system, especially on that polemic and multidisciplinary
Considering the complexity of interrelation between organizations and the environment, methodologies to caracterize and
evaluate environmental performance have become very important to their strategic planning.
On this paper, will be presented the main results of actual discussions about environmental performance, and wiIl be pointed
out the requirements of BS 7750 and EMAS standards related to this subject.
On the last years have been created many management tools and programs related to environmental protection, following
society concern about this subject. Among them it can be emphasized the Responsible Care Program, International Chamber
of Commerce (ICC) Business Charter for Sustainable Development, Environmental Auditing Programs and the EMS
Into these management tools and programs it can be identified the concept of environmental performance (EP) improvement.
On the ICC Business Charter for Sustainable Development, for example, it was defined 4 evolution levels on environmental
protection, from legal compliance (level 1) to total quality approach (level 4). Besides, it was defined a management tool to
evaluate EP – The ESAP (Environmental Self Assessment Program).
In the Responsible Care Program elements is being also considered a criteria to evaluate EP.
EMS standards, on the other hand, are being caracterized as EP standards, based on environments effects/impacts.
The actual discussions on EMS standards concentrate strongly on the way to evaluate the EP. On this paper it will be analised
the main topics of this discussions, related to ISO 14000, BS 7750, and related to existing EMS certification criteria, especially
the NACCB (National Accreditation Council for Certification – Great Britain).
BS 7750 scope consider that “the standard does not itself state specific environmental performance criteria, but requires
organizations to formulate policies and objectives taking into account information about significant environmental effects”.
The concept of EP is, therefore, related to the management of environmental effects.
The BS 7750 definition of continual improvement show it too:
“Year-on-year enhancement of overall environmental performance, not necessarily in all areas of activity, resulting from
continuous efforts to improve in line with environmental policy. This enhancement will, where appropriate, be achieved by
measures such as:
a) Developments in products, services, processes and facilities;
b) Enhanced product quality, operational efficiency and resource utilization;
The application of measures, with a view to reducing adverse environmental effects to levels not exceeding those
corresponding to economically viable application of best available technology”.
BS 7750 main requirements related to EP are diffused on different item:
Environmental Policy – it shall include a commitment to continual improvement of environmental performance;
Environmental Objectives and targets – they “shall quantify wherever practicable the commitment to continual improvement in
environmental performance over defined time-scales”.
Operation Control – “criteria for performance, which shall be stipulated in written standards”.
It is important to emphasize that BS 7750 “does not establish absolute requirements for EP, beyond compliance with
applicable legislation and regulations, and a commitment to continual improvement”.
It is useful to say that applicable legislation refers to the federal, state and city ones related to the organization activities and
environmental significant effects.
It means that the organization itself determines its EP improvement rhythm, based on its significant effects, specific conditions,
its financial conditions and its commitment to continual improvement of EP, expressed on its Environmental Policy.
The European Eco Management and Audit Scheme – EMAS has its principles and bases established by the Regulation (CEE)
Number 1836/93, of 29/06/93.
This regulation considered 18 months, after its publication, to structure the certification and accreditation framework. In fact,
the system was put on practice on April/95, 21 months after its publication.
The regulation states, as its objectives:
– Evaluation of organization EP’s;
– Gives information to the public about this EP.
EMAS adopts as its EMS reference the BS 7750 standard. Thus, it contains basically the same requirements that the British
one. However, it establishes an additional requirement related to the publication of an Environmental Statement, which must
be verified after each individual audit or audit cycle. This environmental statement shall include:
– A description of the installation activities;
– A general view of the significant environmental aspects:
– A brief of the quantitative data related to the environmental aspects;
– Other factors related to the environmental management;
– A presentation of the environmental policy, program and management system;
– Next statement presentation date;
– Identification of the accredited environmental verifier.
Besides, it must be presented annually an simplified environmental statement including, at least, a brief of quantitative data of
environmental aspects.
EMS certification involves a bigger complexity when talking about EP evaluation (EPE). On one side, if the certificate assures
full legal compliance, it results duplication of inspection and enforcement activities of the environmental agencies, with no
authority to do that.
On the other side, a certification assessment concerned only with systems aspects (not considering EP), would result on lose
of certificate credibility to the public, because it can be given to an organization that doesn’t comply with applicable legislation.
The criteria that is being adapted by European accreditation entities (EAC – European Accreditation of Certification, NACCB –
Great Britain and the Dutch RVC – Raad vor Certificatie) considers an intermediate solution between the two extremes: the
certificate assures that the operator knows the applicable legislation and regulations; communicates itself with environmental
licensing agencies in the event of any fail to meet the license requirements; records properly EP and takes adequate
corrective actions when necessary.
Thus, it would be a non conformity:
– Absence of notifications to the environmental licensing agency in cases of fail to comply with the license requirements;
– Conscious incorrect statements by the company to the public;
– Structural situations like, for instance, absence of legal parameter records, or absence of adequate technical means to its
– Absence of corrective/preventive actions to deal properly with legal non conformities.
The NACCB criteria requires, with relation to EP, that the “certification body must (…) have the competence to determine
– Performance in the areas of significant environmental effects is being monitored;
– The results are being appropriately reviewed and analyzed;
– Appropriate corrective action is being taken;
– The links are c1early evident between environmental effects, policy, objectives, responsibilities, programmes/procedures,
performance records, audit and review”.
According to this criteria, the “certification body must also be competent to:
– Interrogate for completeness the operator’ s register of legislative, regulatory and other policy requirements, so as to be able
to assess whether the policy and objectives have been soundly reached as the basis for its improvement programme; (…)
– Establish that the operator’s objectives and targets for improvement take into account (or provide justification for not so
doing) the following key factor in Annex A4 of BS 7750:
The likely environmental significance of the effect in question, in relation both to other effects of the organization, and to
effects from other sources upon the environmental medium or target organism/ecosystem in question;
b) Any regulatory requirements relating to the effect in question;
c) The extent of concern of other interested parties about effects of the type in question;
d) Existing knowledge, in the organization or elsewhere, about the effect”
ISO 14000 series, through its distincts standards, intend to deal with EP deeply that the others EMS standards. For this
reason, it was created a specific subcommittee (SC4) encharged of creating criterias to EP.
Talking about the ISO 14001 standard – Specification for Environmental Management Systems, it can be told that its
requirements are the same as the BS 7750 ones. The recommendations from the ISO 14000 Standard EMS – General
Guidelines and Principles Systems and Supporting Techniques, includes additional considerations about the development of
Environmental Performance Indicators (EPI’ s), related to the environmental significant effects. It gaves examples of this EPI’
s, such as: tonnes of raw material used; waste produced per tonne of finished product, number of environmental
incidents/accidents; investment in environmental protection. Besides, this standard suggest that EMS implementation consider
6 levels (the 4 more evoluted aline with that included on the ICC Business Chart for Sustainable Development).
This approach of EP on TC 207 will be complemented by the future standards ISO 14030, that deal specificly with EPE.
Inicially, it would be developed 2 standards on SC4, (generic and industry sector EPE), which changed to EMS EPE standard
(working group #1) and working on organizations for the environment (working group #2). The development rate of these
standards is slower than the EMS ones. It is intended to aprove these standards at 1998.
As it is a new subject all over the world, it was suggested by SC4 that it would be done an application pilot program on this
standards before its presentation as a final draft.
Some conceptuals matters are being discussed by SC4 members:
a) Is an EPE a system or a tool?
b) Is an EMS a measurement/evaluation system or a system for setting strategies?
c) What is the role of EPE within an EMS?
Questions a) and b) linked with EPE concept and amplitud will certainly define the role it has on EMS. If EPE is looked as a
tool to measure/evaluate EP against planned conditions, it will limit itself to the verification activities and comparison with
established objectives, targets and control criteria. If it is focused as a system to define, evaluate and review objectives and
targets, EPE will play a central role on EMS, supporting continual improvement cycle.
It seems that actual discussion on SC4 lead to an EPE 100ked as a tool to measure, evaluate and describe EP against
defined criteria. For this objective, the methodology will be based on the selection of EPI’ s, which will measure EP against
defined standards, showing improvements opportunities. Such reference standards may be obtained, for instance, using
available technology, best industry practices, bench marking the view of interested parties, existing legal standards.
Some principles related to the EPI’ s selection will be considered on these standards, assuming that they are:
Relevant to the interested parties
Practical and viable
Value neutral
EMS standards put strong emphasys on EP, that requires an organization to fully comply with legal requirements, and
demonstrate its commitment to continual improvement over time.
Probably firsts certified EMS’s will be more compliance oriented. However, with the experience gained in the following years
EP will go far and far beyond legal compliance. At that moment, principles and methodologies to plan and evaluate EP will
play a very important role to optimize EMS, and bring a cost-effective continual improvement.
– BSI, BS 7750/94 – Specification on Environmental Management Systems
– Conselho das Comunidade Européias, Regulamento (CEE) n° 1836/93, de 29/06/93 in Jornal Oficial das Comunidades
Européias, nº 2 168/1, 10.07. 93.
– Global Environmental Management Iniciative, Environmental Self Assessment Program.
– InternationaI Environmental Systems Update, Vo1.2, Number 2, Feb.95
– ISO TC 207/SCI, Committee Draft ISO/CD 14000.
– TC 207/SCl, Committee Draft ISO/CD 14001.
– National Accreditation Council for Certification Bodies – NACCB, Environmental Accreditation Criteria, Jan/95.

Autor: Michel Epelbaum

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