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Successful Practices
       of Environmental Management Systems
       in Small and Medium-Size Enterprises


       A North American Perspective




       Commission for Environmental Cooperation
ACKNOWLEDGMENTS

This report was prepared by Tim Whitehouse, Head of the Law and                               Peer reviewers also provided extremely valuable comments
Policy Program of the Secretariat of the Commission for                                 and ideas during the development of this report. They provided
Environmental Cooperation (CEC). Morgan Rider, member of the                            many insights into the issues faced by small and medium-size busi-
environmental consulting firm Ecology and Environment, Jerry                            nesses in implementing environmental management systems and
Speir, an attorney practicing in New Orleans, Louisiana, and Dixon                      into the types of resources available to help these businesses
Thompson, professor of environmental science at the University of                       improve their environmental performance. These reviewers were
Calgary’s School of Environmental Design assisted in the design,                        Leonardo J. Cárdenas, Principal Consultores en Calidad Ambiental
research and writing of this report.                                                    SA de CV; Raymond P. Côté, professor, School for Resource and
     The Secretariat is grateful to Environment Canada, Mexico’s                        Environmental Studies, Dalhousie University; Margarita Ferat Toscano,
Federal Attorney for Environmental Protection ( Procuraduría                            environmental corporate manager, DESC SA de CV; Louise Millette,
Federal de Protección al Ambiente) and the US Environmental                             director, Department of Civil, Geological and Mining Engineering,
Protection Agency for their comments on this report. The views                          École Polytechnique de Montréal; David Ronald, executive director,
expressed in this report are not necessarily those of the govern-                       Multistate Working Group; and Richard P. Wells, president,
ments of Canada, Mexico or the United States.                                           Lexington Group.




The Commission for Environmental Cooperation (CEC) was established under the            Commission for Environmental Cooperation
North American Agreement on Environmental Cooperation (NAAEC) to address envi-          393, rue St-Jacques Ouest, Bureau 200
ronmental issues in North America from a continental perspective, with a pa rt i c u-   Montréal (Québec) Canada H2Y 1N9
lar focus on those arising in the context of liberalized trade.                         E-mail: info@cec.org
                                                                                        http://www.cec.org
This publication was prepared by the Secretariat of the CEC. The views contained
herein do not necessarily reflect the views of the CEC, or the governments of Canada,
Mexico or the United States of America.                                                 ISBN: 2-923358-29-5

Reproduction of this document in whole or in part and in any form for educational or    © Commission for Environmental Cooperation, 2005
nonprofit purposes may be made without special permission from the CEC
Secretariat, provided acknowledgement of the source is made. The CEC would              Legal Deposit-Bibliothèque nationale du Québec, 2005
appreciate receiving a copy of any publication or material that uses this document as   Legal Deposit-Bibliothèque nationale du Canada, 2005
a source.
                                                                                        Disponible en español - Disponible en français

                                                                                        Design: Associés libres, Montreal

                                                                                        December 2005

          Printed in Canada on paper containing 100% post-
          consumer waste fiber.
CONTENTS

                                          1. Introduction   2

          2. Defining Small and Medium-Size Enterprises     4
               and Environmental Management Systems

   3. Are Environmental Management Systems Effective?       9

4. The Benefits and Common Characteristics of Successful    12
                     Environmental Management Systems

        5. Drivers and Barriers to EMS Adoption by Small    15
                            and Medium-Size Enterprises

                   6. Technical Assistance and Outreach     18

                       7. Incentive Programs and Policies   24

                                     8. Future Directions   27

                          Appendix A. Useful Web Sites      29

           Appendix B. 10 Elements of an Environmental      30
                                 Management System

                                              References    31
1. INTRODUCTION



    his report examines the use of environmental             1. designed with a strong business case in mind
T   management systems (EMSs) in small and
medium-size enterprises (SMEs) in Canada,
                                                             2. managerial support and commitment of
                                                             resources
Mexico and the United States. In doing so, it pro-           3. engaged employees
vides a North American perspective on success-               4. integrated into business
ful practices and some of the issues faced by                5. clearly defined objectives and targets
SMEs in developing and implementing these sys-               6. continual monitoring and measurement.
tems. It also offers some suggestions for contin-
ued cooperation between the governments of                         Not all EMSs, however, are effective in
Canada, Mexico and the United States on promot-              improving environmental performance. Most
ing EMSs.                                                    SMEs face few incentives and many difficulties
       Over the past decade, the three govern-               in implementing environmental management
ments have promoted the use of EMSs to help                  systems. The owner of a business must believe
companies improve their environmental per-                   that an EMS will create real tangible value for
formance and move beyond compliance with                     the business. Yet most SMEs do not know what
the law. The Commission for Environmental                    an EMS is and, if they do, how it could benefit
Cooperation (CEC) has served as a forum in                   their business. Even if they are familiar with the
which the three governments could share their                concept of an EMS, many smaller businesses
experiences, practices, and successes on the use             lack the technical expertise and resources
of EMSs in North America. In June 2000, for                  needed to develop and implement one.
example, the CEC published Improving Envi-                         Although business needs may ultimately
ronmental Performance and Compliance: 10                     determine whether an SME implements an EMS,
Elements of Effective Environmental Manage-                  government or private sector technical assistance
ment Systems, which described those elements                 and outreach efforts are often crucial to provid-
that the three governments agreed were impor-                ing the conditions under which businesses—par-
tant to address in implementing EMSs (CEC                    ticularly small and micro-businesses—are likely to
2000). The CEC has also encouraged a North                   implement a successful EMS. Continued cooper-
American dialogue on the use of environmental                ation among the governments of Canada, Mexico
management systems through its support of                    and the United States could help improve the
and participation in numerous workshops and                  delivery of sector-specific information and techni-
forums, including most recently those of the                 cal assistance and specific advice on EMS
North American Pollution Prevention Partner-                 methodologies to SMEs.
ship, Mexico’s Pollution Prevention Roundtable,
the Auditing Roundtable and the Canadian                     Organization of This Report
Environmental Auditing Association.                          The chapters that follow describe a North
       In recent years, the private sector has devel-        American perspective on the use of environ-
oped various types of EMSs for identifying and               mental management systems in small and medi-
managing the impacts that commercial, industrial             um-size enterprises. The definitions of an EMS
and service operations have on the environment.              and a SME in Chapter 2 are followed by a closer
Although the use of EMSs is becoming more                    look in Chapter 3 at the effectiveness of envi-
common among larger companies, their use by                  ronmental management systems in improving
small and medium-size enterprises is less com-               environmental performance. Chapters 4 and 5
mon.                                                         then look at the benefits and characteristics of a
       A successful EMS can enhance efficiency               successful EMS and the drivers and barriers to
and lower costs, reduce resource use and waste,              EMS adoption by small and medium-size busi-
help to ensure compliance with regulatory                    nesses. Chapters 6 and 7 review the technical
requirements, encourage employee involvement                 assistance and outreach, and the incentive pro-
in environmental performance and improve rela-               grams and policies in the three countries. Chap-
tions with customers. In examining a variety of              ter 8 concludes by examining areas for future
experiences in North America, this report identi-            cooperation by the three governments on EMS
fies six common characteristics of successful EMSs           promotion in North America. The two appen-
adopted by small and medium-size enterprises:                dices to the report provide general information




2   E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
on environmental management systems.
Appendix A lists some useful web sites in addi-
tion to those found as reference to this text, and
Appendix B presents the CEC’s "10 Elements of
Effective Environmental Management Systems."
       With the growing integration of the North
American economy under the North American
Free Trade Agreement (NAFTA), the CEC is in a
unique position to step back and examine the
development of EMS policies and programs in
all three countries. Such an examination can help
those promoting environmental management
systems in Canada, Mexico and the United
States to learn from the experiences of the other
countries and can help to inform and stimulate
discussion and critical comment among those
assisting small and medium-size enterprises with
environmental issues.




3   A NORTH AMERICAN PER SPECTIVE
2. DEFINING SMALL AND MEDIUM-SIZE
                                                   ENTERPRISES AND ENVIRONMENTAL MANAGEMENT
                                                   SYSTEMS
                                                       mall and medium-size enterprises in North                percent of their gross domestic product (GDP)
                                                   S   America vary widely in their impacts on the
                                                   environment. An environmental management
                                                                                                                and over half of their private sector employment.
                                                                                                                In the manufacturing sector, SMEs generate 55
                                                   system offers the methodology a company                      percent of manufacturing employment in Canada,
                                                   needs to identify and implement ways in which                66 percent in Mexico and 41 percent in the
                                                   to improve the environment both inside and out-              United States (OECD 2002).
                                                   side a plant or business, from mere good house-                    Although most SMEs serve local markets,
                                                   keeping steps to strategies to prevent pollution.            they are increasingly operating as part of a glob-
                                                         This chapter examines the various defini-              al marketplace, purchasing products produced
                                                   tions of small and medium-size enterprises and               abroad, supplying multinational companies and
                                                   some of the different types of environmental                 selling directly to overseas buyers. In North
Small and Medium-Size Enterprises?                 management systems in the three countries.                   America, SMEs play an important role in the
The threshold of 500 employees guides the          Although the definition of a small and medium-               market-driven coordination of production across
classification of small and medium-size enter-     size enterprise varies from country to country, it           the US-Mexico and US-Canada borders, espe-
prises (SMEs) in Canada, Mexico and the
United States. Environment Canada typically        is useful to examine SMEs as a general category.             cially in sectors such as automobile, telecommu-
classifies enterprises with less than C$50 mil -   These kinds of enterprises generally have fewer              nications equipment, computer, electronic
lion in annual revenues that are not wholly        resources to address their environmental impacts             products and textiles and apparel.
owned subsidiaries as follows: less than 5
employees, microenterprise; 5–49 employ-           and are thought to be less likely to implement                     SMEs face widely differing environmental
ees, small enterprise; 50–499 employees,           EMSs than larger companies. They also do not,                issues based on the economic sector, employee
medium-size enterprise (Environment                by most definitions, have a parent company on                base and jurisdiction in which they operate. The
Canada 2003).
     The medium-size category is not com -
                                                   which to rely for assistance. Despite these limi-            requirements, demands, pressures and issues
monly used in the United States, and the US        tations, SMEs can use the basic methods of                   they face will more often resemble those faced
Environmental Protection Agency considers a        implementing an EMS as described in this chap-               by companies in their own economic sector,
small business for research grant programs to
                                                   ter to integrate environmental planning into their           regardless of size, than those in other sectors.
be a for-profit organization with no more than
500 employees that is not dominant in the          everyday business practices.                                 In addition, within the SME category differ-
field of operation. For Performance Track                                                                       ences often exist in the technical capabilities of
Purposes (see Chapter 7), a small business is      What are Small and Medium-Size                               small and medium-size businesses, with medi-
defined as a facility with fewer than 50 employ-
ees. These facilities may be part of larger        Enterprises?                                                 um-size business much more likely to have
organizations. The US Small Business               SMEs are found in the largest and most dynamic               engineering expertise than small enterprises,
Administration has devised sector-specific defi-   sectors of the North American economy, rang-                 especially related to energy efficiency and con-
nitions with both employee and revenue limits.
See <http://es.epa.gov/ncer/sbir/                  ing from those that are pollution-intensive and              servation.
2005SBIRfactsheet.pdf> and                         resource-intensive, such as manufacturing and                      SMEs, even those in the retail sector, can
<http://www.sba.gov/size/>.                        natural resource extraction, to those that are               have significant impacts on the environment,
     In Mexico, Profepa follows a classification
(by number of employees) established by the
                                                   more environmentally benign, such as retail. They            including those from nonregulated activities
Secretary of Economy in 1999:                      often face unique environmental challenges that              such as resource consumption, packaging and
            Industrial   CommercialService         are related to their size and their place in the             methods of hazardous and nonhazardous waste
Micro       0–30         0–5       0–20            economy. (See Table 2.1)                                     disposal. According to Environment Canada
Small       31–100       6–20      21–50                 The economic importance of SMEs in                     (2003), of the 2 million Canadian SMEs, the
Medium      101–500      21–100    51–100          North America is significant. Over 98 percent of             400,000 most pollution-intensive are in the agri-
                                                   businesses in Canada, Mexico and the United                  culture, primary and manufacturing sectors.1 A
Mexico’s National Institute of Statistics,
Geography and Informatics Instituto Nacional       States are small and medium-size enterprises.
de Estadística Geografía e Informática—            SMEs are found in all the economic sectors of                1. The primary sector includes activities such as fisheries, mining,
INEGI) has more specific classifications.          the three countries, producing approximately 40              forestry and oil and gas extraction.




                                                   Table 2.1 Distribution of Employment in Manufacturing by Size Class
                                                   Country         0–9             10–49           50–99             100–499             500+                                 Total
                                                   Canada          4.1             17.8            8.8               24.2                45.0                                   100
                                                   Mexico          18.9            12.0            7.5               27.6                34.0                                   100
                                                   United States 3.6               4.1             16.0              17.4                58.9                                   100
                                                   Source: OECD 2002.




                                                   4   E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
study prepared for the Organization for Economic            with its "Pollution Prevention Pays" program,
                                                  Co-operation and Development (OECD) found                   and Dow, with its "Waste Reduction Always
                                                  that SMEs in the United States are significant              Pays" (WRAP) program. In the 1980s, EMS pro-
                                                  contributors of pollution in three branches of              grams largely focused on due diligence and
                                                  manufacturing: chemicals, primary metals and                compliance with laws and regulations as well as
                                                  building materials (e.g., stone, clay and glass).           ways to cut costs in disposing of wastes and
                                                  The largest impacts from these SMEs were on                 treating effluents. Also in the 1980s, trade asso-
                                                  biological oxygen demand (BOD) in water and                 ciations began to develop codes of environ-
                                                  suspended particulates in air, followed by the              mental practices, which approximated the
                                                  release of toxic chemicals (OECD 2002). But                 definitions of environmental management sys-
                                                  those statistics for the United States were devel-          tems (Pacific Institute for Studies in Develop-
                                                  oped in a study done specifically for OECD;                 ment, Environment, and Security 2000).
                                                  generally, "comprehensive pollution or resource
                                                  consumption statistics for SMEs do not exist,               EMS Models
                                                  making it difficult to determine their contribution         Today, EMSs can range in complexity from sim-
Total Quality Management                          to environmental degradation" (OECD 2002).                  ple reminders of regulatory deadlines at a single
Most systematic approaches to addressing                                                                      facility to an elaborate, Internet-based, enter-
performance issues derive from the work of        What Is an Environmental Management                         prise-wide performance management system
W. Edward Deming, the US statistician who         System?                                                     that tracks regulatory requirements, assigns
is credited with dramatically improving the
performance of Japanese industry after World      An environmental management system is a tool                tasks, controls documentation and records, pro-
War II with a system that has come to be          used by a company to identify measure and                   vides training, and shares information across mul-
known as Total Quality Management (TQM).          manage the effects of its activities on the envi-           tiple operations and facilities around the world.
Deming also popularized the plan–do–
check–act cycle that is at the root of all such
                                                  ronment. An EMS sets out the company’s goals                       EMSs are most effective when they are
systems: identify and analyze the problem         for environmental performance and a plan for                part of normal business activities rather than
(plan), develop and implement solutions (do),     achieving those goals. Ideally, company man-                treated as separate programs or initiatives.
evaluate and measure the results (check), and
                                                  agers will set goals in areas such as compliance            Although businesses typically have many ele-
fix the problems identified and incorporate
the lessons learned into a feedback loop that     with environmental laws, minimization of risks              ments of an EMS already in place, the EMS pro-
begins the process anew (act). The feedback       to human health and the environment, use of                 vides a systematic way to integrate those efforts
loop involves all personnel and elements of an    natural resources, and prevention and reduction             and direct them toward company-established
organization and runs counter to traditional
top-down "management by objective"                of pollution.                                               goals. The significant range and variations of
approaches. Environmental management sys-              The evolution of EMSs in North America                 EMSs can be attributed to the differences
tems turn the TQM process to a specific con-      can be traced to the 1970s and the pollution                among organizations in size, activities, impacts,
cern for reducing environmental impacts.
                                                  prevention programs of companies such as 3M,                regulatory requirements, corporate culture and
Source: Welch 1998.

                                                  Figure 2.1 BC Hydro’s Environmental Management System

                                                                                         Environmental
                                                                                      Responsibility Policy




                                                        Management Review

                                                                                                                   Planning
                                                                                                                   • Identifying aspects, impacts
                                                                                                                     and operational controls


                                                                                    EMS
                                                  Checking and Corrective Action                                   • Indentifying legal and other
                                                  • Monitoring and measuring                                         requirements
                                                  • Process improvement                                            • Meeting objectives, targets
                                                  • Records                                                          and environmental programs
                                                  • EMS compliance audits



                                                                                   Implementing and Operation
                                                                                   • Defining training needs
                                                                                   • Implementing training
                                                                                   • Internal communication
                                                                                     and reporting
                                                                                   • External communication                Source: Industry Canada,
                                                                                   • Document control                      <http://www.strategis.ic.gc.ca/epic/internet/
                                                                                   • Contractors and suppliers             incsr-rse.nsf/en/rs00122e.html>.




                                                  5   A NOR TH AMERICAN PER SPECTIVE
policy commitments. Figure 2.1 depicts the                   certification by accredited certificate bodies.2
                                                EMS of BC (British Columbia) Hydro and is rep-                     The European Office of Crafts, Trades and
                                                resentative of the structure of many EMSs.                   Small and Medium-Sized Enterprises for Stan-
                                                                                                             dardisation (Le Bureau Européen de l’Artisant,
                                                The International Organization for                           et des Petites et Moyennes Enterprises pour la
                                                Standardization (ISO) 14001                                  Normalisation), better known by its acronym
                                                The most widely recognized model for an EMS                  NORMAPME, has formally asked the ISO to
                                                is the International Organization for Standard-              "explore alternative ways to use the environ-
                                                ization (ISO) 14001 standard. This standard,                 mental management system standard ISO 14001
                                                which is applicable to organizations of all types            that are in line with their members’ limitations."
                                                and sizes, is based on five components:                      NORMAPME seeks changes that might include
                                                                                                             allowing an incremental implementation of ISO
                                                1. An environmental policy that commits the                  14001 or allowing organizations to be certified
                                                organization to "prevention of pollution," "con-             in batches, sharing procedures and administra-
                                                tinual improvement" and compliance with "rele-               tive costs. The ongoing revisions of ISO 14004
                                                vant environmental legislation and regulations."             are intended to simplify EMS requirements for
                                                2. Planning to implement the environmental                   SMEs in order to facilitate implementation. ISO,
                                                policy, which entails identifying all of an organi-          through its Sub-Committee 1 of Technical Com-
                                                zation’s interactions (activities, products or serv-         mittee 207, has formed an ad hoc group to study
                                                ices) with the environment (its "environmental               EMS penetration among small businesses, and a
                                                aspects") and designating the "significant"                  report is expected in September 2005.3
                                                aspects and setting quantifiable objectives and
                                                targets for addressing those significant aspects.            The Eco-Management and Audit Scheme
                                                3. Implementation and operation, which                       Many European countries require large manufac-
                                                requires an organization to ensure the availabili-           turing facilities to implement the Eco-Management
ISO 14001 Trends in North America               ty of resources, define roles and responsibilities,          and Audit Scheme (EMAS). The components of
As of December 2003, the breakdown of           develop documented procedures, emergency                     EMAS are similar to those of ISO 14001. However,
North American certifications for ISO 14001     preparedness plans and ensure employee com-                  EMAS has two significant additions: a baseline
was Canada, 1,274; Mexico, 406; and the
United States, 3,553 By contrast, in 1998 the   petency, training and awareness.                             environmental assessment and a public environ-
breakdown was Canada, 104; Mexico, 39;          4. Checking and corrective action to measure                 mental performance report. Many companies
and the United States 291. See                  and track the performance of the system against              outside Europe have also chosen to implement
<http://www.iso.org/iso/en/iso9000-
14000/pdf/survey2003.pdf>. No specific
                                                its own goals and to evaluate compliance with                the EMAS system or variations.
numbers exist for SMEs, which are more          the relevant laws and regulations. The organi-
likely to use third-party registrars and        zation must also identify, investigate and correct           The CEC’s "10 Elements of Effective Environ-
therefore are less likely to be reported        any nonconformities. The organization must                   mental Management Systems"
in the ISO system.
                                                ensure that internal audits are conducted.                   In June 2000, the Commission for Environmen-
                                                5. Review of the EMS by top management "to                   tal Cooperation published the "10 Elements of
                                                ensure its continuing suitability, adequacy, and             Effective Environmental Management Systems"
                                                effectiveness."                                              (CEC 2000). The "10 elements" were negotiated
                                                                                                             by Canada, Mexico and the United States just
                                                       The ISO standard focuses on conformance               after the ISO 14001 standards were published
                                                with established policies, plans and procedures,             and served as the first general policy statement
                                                but it does not specify requirements for environ-            by the three governments on what they
                                                mental performance beyond compliance with the                believed were important features of an EMS.
                                                relevant legislation. Organizations are, however,            The "10 elements" are generic in nature and not
                                                free to set goals that exceed compliance                     specifically geared toward small and medium-
                                                requirements.                                                size enterprises. Notably, they place greater
                                                       Companies implementing ISO 14001 may                  emphasis on compliance with environmental
                                                choose to have their EMS certified. They can seek            regulations than the ISO 14001 standard. Like
                                                third party certification from either accredited             the ISO standard, the "10 elements" state that a
                                                certificate bodies (those recognized by a national           company’s environmental policy should include
                                                accreditation body) or no accredited bodies. Most            a provision for compliance with environmental
                                                firms seeking certification employ accredited                requirements. But the "10 elements" go beyond
                                                bodies; these may be perceived on the market as              the ISO in stating that an EMS should establish
                                                having greater credibility, although a firm that
                                                implements ISO 14001 solely for internal man-
                                                                                                             2. For more on ISO certification, see <http://www. iso.org/iso/en/
                                                agement purposes (without expectation of ben-                iso9000-14000/basics/general/ basics_5.html>.
                                                efits from regulators, customers or public                   3. See <http://www.iso.org/iso/en/CatalogueDetailPage.
                                                perception) may choose not to seek third party               CatalogueDetail?CSNUMBER=31808>.




                                                6   E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
objectives and targets for achieving and main-            ples tend to be those tailored to a specific
taining compliance with environmental require-            industry and designed with input from the
ments and a commitment to continuous                      industry itself. For example, the Texas Commis-
improvement in environmental performance                  sion on Environmental Quality (TCEQ) developed
(see Appendix B for the CEC’s "10 elements").             a sample EMS for small businesses in the metal
                                                          finishing industry. (See Table 2.2) The EMS for
A Sample EMS from the Metal Finishing                     the fictitious company, Papa Plating, covers all
Industry                                                  on-site operations, including metal finishing and
Various sample EMSs are available for small and           processing activities, groundskeeping, offices
medium-size enterprises. The most useful sam-             and waste disposal.


Table 2.2 Selected Aspects of Sample EMS Addressing Water Usage
Form 7: Environmental Management Action Plans
      Significant Environmental Aspects      Water Use
                                   Goal      Reduce the amount of water purchased by 50%
                            Action Plan      Analyze how water is used and what can be done to
                                             minimize water use
                                             Consider different potential rinsing methods
                         Review Cycle        Willie Scott will review every 6 months


Form 8: EMS Work Instructions
Significant Environmental        Associated Job              Work Instructions
         Aspects                   Functions                    Needed                 Responsible Person

                                                           Yes – employees should
                                  Parts Rinsing          monitor the drip time over    Plating supervisor
                                                         the various rinse tanks and
                                                          withdraw the parts at the
                                                                proper speed
         Water Use
                                                          Yes – employees should
                                                           rack parts to minimize
                                  Parts Racking          solution dripping on other    Plating supervisor
                                                                    parts


Form 9: Alternatives Identification — Significant Environmental Aspect: Water Use

    Activity              Current Practice              Potential Alternatives

    Rinsing methods      Dip rinsing                      Try spray rinses in the various processes to try
                                                          to improve rinsing performance and decrease
                                                          water consumption

    Water flow           Rinse water is being             Research the use of conductivity meters
                         flowed at a high rate            and/or flow restrictions
                         during production

    Treatment            Currently chemically treated     Consider the use of reverse osmosis and/or ion
                         and discharged to waste-         exchange after the initial treatment and reuse
                         water treatment facilities       the treated effluent back in our process

    Rinse tank           None                             Consider the use of air agitation in the rinse
                                                          tanks to improve agitation the rinsing process

Source: TCEQ




7    A NOR TH AMERICAN PER SPECTIVE
Papa Plating’s EMS contains elements of
ISO 14001 and the CEC’s "10 elements." The
EMS provides a sample action plan on water
use, energy use, sludge generation and dispos-
al, metal use and use of natural resources,
organic emissions from a degreaser and human
exposure to toxic materials and chromium emis-
sions. A look at the selected portions of an EMS
regarding water aspects of the Papa Platings
EMS usefully illustrates some of the specific ele-
ments of an EMS.
      Papa Plating’s system is just one example
of how to create an EMS. An environmental
management system can be designed to
address the needs of any size organization.
Standards groups, trade associations and gov-
ernments have all designed different types of
environmental management systems and pro-
grams to help businesses improve environmen-
tal performance by integrating environmental
planning into everyday business processes.




8   E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
3.ARE ENVIRONMENTAL MANAGEMENT SYSTEMS
                       EFFECTIVE?

                           ecent studies indicate that not all environ-                        and assistance from their parent organizations,
                       R   mental management systems lead to
                       improved environmental or business perform-
                                                                                               but they occur in privately held and govern-
                                                                                               ment facilities as well." The NDEMS study is
                       ance. However, several projects and numerous                            inconclusive on the financial benefits of an
                       case studies of successful EMS practices in                             EMS, but notes that benefits were "moderately
                       small and medium-size enterprises support the                           impressive" for the facilities that realized them.
                       proposition that an effectively designed EMS                            Thirty-two facilities reported quantified mone-
                       can, under the right circumstances, significantly                       tary benefits from EMS adoption; the average
                       help a company improve its environmental per-                           net benefit for those reporting a benefit through
                       formance and bottom line. Because not all                               the first three years was $90,320. (NDEMS
                       EMSs produce positive benefits, it is important                         2003)
                       to understand the potential benefits of an EMS,                                One study completed by the University of
                       the common characteristics of successful EMSs,                          Sussex in July 2000 compared EMS use in EMAS
                       the drivers and barriers to EMS implementation,                         and ISO systems in 280 European companies at
                       and the programs available to help SMEs                                 430 production sites and found no statistically
                       improve their performance. These subjects are                           significant relationship between the adoption of
                       covered in the chapters that follow.                                    a formal EMS and improved environmental per-
                                                                                               formance. The companies included 9 computer
                       Empirical Studies of EMSs                                               companies, 58 electric power generators, 26 fer-
                       Empirical studies of the performance of EMSs                            tilizer manufacturers, 90 pulp and paper produc-
                       have only recently begun to emerge. One of the                          ers, 46 printers and 45 textile finishers.4
                       only studies in North America was conducted in                                 Another study of electronic firms observed
An effectively         the United States by the University of North                            that firms that adopted ISO 14001 were able to
                       Carolina and the Environmental Law Institute                            catch up to industry best practices, especially if
designed EMS can,      between 1997 and 2002. The National Database                            they produced significant toxic emissions
                       on Environmental Management Systems                                     (Russo 2000). A study conducted in the auto-
under the right        (NDEMS) study examined environmental per-                               motive supply sector before Ford and General
circumstances,         formance data at 83 facilities over a five-year
                       period. Ultimately, 30 facilities completed all five
                                                                                               Motors required their suppliers to be ISO-certi-
                                                                                               fied found minimal reductions after ISO 14001
significantly help a   years of the study. The participating facilities                        adoption. In terms of toxic releases and compli-
                       ranged from large, publicly traded major manu-                          ance with regulatory requirements, environ-
company to improve     facturers and electric utilities to small businesses                    mental performance was about the same in
                       such as auto parts suppliers and electroplaters                         facilities that had adopted EMSs under ISO
its environmental      and government organizations, including military                        14001 and those that had not (Matthews 2001).
                       bases and municipal water treatment plants.
performance and        Approximately 70 percent of the organizations                           Projects and Case Studies
                       participating in the NDEMS study were part of a                         Although little empirical work exists on the
bottom line            larger business or government organization.                             impacts of EMS adoption, the literature and
                              The final report of the study concluded                          case studies contain valuable information on
                       that evidence from the pilot facilities "suggests                       how companies have used EMSs to improve
                       that the introduction of an EMS can be expect-                          environmental and business performance.
                       ed to be at least somewhat beneficial to the                                 The US Environmental Protection
                       environmental performance of most facilities, as                        Agency’s web site includes a case study index
                       well as to their operating and management effi-                         with links to EMS success stories, several of
                       ciencies, and in some cases to their regulatory                         them on SMEs.5 The EPA case studies generally
                       compliance patterns. These results are more                             include an introduction to the facility, an
                       likely for facilities that are subsidiaries of pub-                     overview of the planning and implementation of
                       licly traded corporations, owing to their greater                       the EMS, a list of the benefits achieved, and a
                       access to management capabilities, resources,                           description of the lessons learned. One case
                                                                                               study, for example, explains how the Mott’s
                       4. See <http://www.environmental-performance.org/analysis/index.php>.   Aspers plant, an apple juice and apple sauce
                       5. See <http://www.epa.gov/ems/studies/index.htm>.                      plant with 378 full-time employees in Pennsyl-




                       9   A NORTH AMERICAN PER SPECTIVE
vania, implemented a EMS that resulted in the       In this project, 11 large companies in Guadala-
                                   production of less solid waste, reduced water       jara, Mexico, signed a voluntary agreement with
                                   usage, increased recycling, savings on energy       Mexico’s Ministry of Environment, Natural
                                   usage and wastewater treatment costs.6              Resources and Fisheries (Secretaría de Medio
                                         The Manual for Implementing EMS in            Ambiente, Recursos Naturales y Pesca—Semar-
                                   SME, issued by the International Finance Cor-       nap), now known as the Ministry of Environ-
                                   poration (IFC), also includes 15 case studies       ment and Natural Resources (Secretaría de
                                   from facilities throughout the world, including     Medio Ambiente y Recursos Naturales—Semar-
                                   the United States, on the actual benefits real-     nat), to mentor small suppliers in implementing
                                   ized by small and medium-size businesses that       EMSs. Within three months of completing the
                                   have implemented EMSs (IFC 2004). Some              formal EMS training, over 80 percent of the 20
                                   summaries of selected case studies from the IFC     participating companies in the GEMP study had
                                   manual appear in Table 3.1.                         reduced their environmental releases, nearly 70
                                         In Mexico, several projects have been         percent had improved their work environment,
                                   undertaken to provide SMEs with technical           and over 50 percent had improved their eco-
                                   assistance in implementing environmental man-       nomic performance.
                                   agement systems. The Guadalajara Environ-                 Slightly less than 50 percent reported
                                   mental Management Pilot (GEMP), financed by         improvements in waste handling, materials and
                                   the World Bank, studied the effects of EMS use      energy efficiency, and compliance. The study
                                   in small and medium-size enterprises in Mexico.     concludes that "gains from good housekeeping
                                                                                       are potentially very large in the case of SMEs,
                                   6. See <http://www.epa.gov/ems/studies/mott.htm>.   and … an EMS provides a means to capture



Table 3.1 Selected EMS in SME Case Studies, Worldwide
Company                            Environmental Benefit                               Cost Savings

Leff-Marvins Cleaners Inc.         Replaced its old equipment with new system to       The company realized a net savings of
                                   recycle PERC (perchloroethylene). Eliminated        US$1,400 per month with the new system.
                                   most VOC (volatile organic compound) emis -
                                   sions and also reduced purchase of PERC from
                                   200 gallons per month to 40 gallons per month.
                                   Reduced hazardous waste stream from over
                                   1,900 gallons of spent PERC per year to just 35
                                   gallons of still residues per month.

Company A                          Introduced more efficient ways of handling          Waste elimination bills were cut by 55 percent.
                                   cardboard. Reduced its waste by 577 tons in         Saved staff time.
                                   the first year.

Mounstevens Ltd., a manufactur-    Increased staff awareness and introduced care-      Expected benefits include cutting waste bills in
ing and retail baker               ful separation of waste.                            half and saving US$8,800 and 26 tons of waste.

Company B                          Instituted a facility-wide municipal waste recy-    Reduced disposal costs and gaenerated enough
                                   cling program, including metal, cardboard,          revenue from marketing the recyclables to fund
                                   paper, wood, plastic and glass. More than 50        the program’s operating expenses, including wages
                                   percent of the municipal waste generated by         and benefits, equipment operation and mainte -
                                   the company is now recycled.                        nance, utility costs and program improvements.

Jamestown Paint Company            Reduced its use of toluol by 95 percent and         Information not available.
                                   xylol by 74 percent by developing water-based
                                   products to replace solvent-based coatings.

A manufacturer of power steering   Installed a green sand recycling system in its      Reduction in the purchase of sand from 4 mil-
gears, engine timing devices and   foundry that puts recovered sand directly back      lion pounds of sand per year to only 80,000
power transmission boxes           into the processing lines, recovering about 95      pounds per year, saving on sand purchase and
                                   percent of silica sand.                             disposal costs.




                                   10    ENVIRONMENTAL M ANAGEMENT SYSTE MS
these gains very quickly." The project’s prelimi-
                       nary findings indicate the following:

                       s The ISO 14001 EMS model can be applied by
                         SMEs without any modifications, with the
                         exception of documentation.

                       s Although the ISO 14001 EMS model is appro-
                         priate for SMEs, most SMEs require substantial
                         implementation support, particularly in the
                         areas of simplified formats, discrete mile-
                         stones, management systems thinking and
Within three months      staff assistance.

of completing the      s The business culture of a firm is probably a
                         more important factor than size in determin-
formal EMS training,     ing whether it can implement an EMS (World
                         Bank 1998).
over 80 percent of
                       Because the GEMP study was undertaken in the
the 20 participating   early stages of EMS implementation, the longer-
                       term economic and environmental affects of
companies in the       EMS implementation have not been analyzed.
                             In another project, Proyecto Administación
GEMP study had         Ambiental Monterrey (PAAM), undertaken in
reduced their          Monterrey, Nuevo Leon, large companies and
                       the Multilateral Investment Fund of the Inter-
environmental          American Development Bank (IADB) supported
                       an effort by the Instituto Protection Ambiental
releases, nearly 70    (IPA), a nongovernmental association of busi-
                       nesses in Monterrey, to train 19 SMEs in the use
percent had improved   and application of a modified environmental
                       management system based on the ISO 14001
their work environ-    model. One of the project objectives was to
                       determine whether EMSs were a useful tool in
ment, and over 50      improving SME environmental performance.
                       Four companies could to point to specific envi-
percent had            ronmental and economic benefits of participating
                       in the project. The project’s report noted that the
improved their eco-    vast majority of the "root causes" of significant
                       environmental problems identified by the firms
nomic performance.     could to be addressed through changes in man-
                       agement practices such as improved mainte-
                       nance, improved procedures and better training.
                       Relatively few of the solutions, according to the
                       report, required significant capital expenditures
                       (Lexington Group 2002).
                             These studies and projects point the way
                       to understanding the potential benefits of an
                       EMS, while serving as a reminder that many
                       obstacles and barriers to effective EMS imple-
                       mentation exist.




                       11   A NORTH AM ERIC AN PERSPE CTIVE
4. THE BENEFITS AND COMMON CHARACTERISTICS
                                                      OF SUCCESSFUL ENVIRONMENTAL MANAGEMENT
                                                      SYSTEMS
                                                           esigning and implementing an EMS can                    longer generating hazardous waste (IFC 2004).
                                                      D    have tangible benefits for business enter-
                                                      prises. A system can help a company to
                                                                                                                   In another example, during the development of
                                                                                                                   its EMS a company in Mexico, Químicos y
                                                      enhance efficiency and minimize resource use                 Papeles del Norte, identified the use of exces-
                                                      and waste, thereby reducing costs, help to                   sive rinse water as a significant environmental
Lower Insurance Costs                                 ensure compliance with regulatory require-                   aspect of its operations: the short production
The most reliable financial quantification of
the benefits of an environmental manage -
                                                      ments, encourage employee involvement and                    runs of incompatible products required the
ment system is often lower insurance costs;           improve relations with customers. Despite vari-              equipment to be rinsed between products. The
companies that minimize risks may receive             ation in the sophistication, scope and achieve-              company implemented a more systematic pro-
better insurance rates. The current case stud -       ments of environmental management systems,                   duction programming to eliminate product
ies, however, provide only a few examples of
small and medium-size enterprises that real-          successful EMSs share common characteristics                 changeovers and increased product storage
ized this benefit. In one example, DESC, a            that are directly related to the benefits of an              capacity. The results were more efficient utiliza-
holding corporation in Mexico that owns sev -         EMS. The benefits and the characteristics of                 tion of product and storage space, water savings,
eral companies from different sectors, includ-
ing the chemical sector, chose to expand its          successful EMSs are described in this chapter.               reduced product waste and improved labor uti-
company-wide EMS to include outsourced                                                                             lization (Lexington Group 2002).
carriers. As part of this effort, suppliers, cus-     The Benefits of Environmental                                       Reduced liability is another financial criterion
tomers, carriers, terminals and all who were
in the supply chain were evaluated. During            Management Systems                                           that can be used to measure the success of an
the first two years, the main focus was the           Various books, articles and studies have identi-             EMS. A court or the government may view a
carriers, who were audited under a specific           fied the benefits an environmental management                company with an EMS in place more favorably
risk reduction program. By developing tools
to evaluate the risks along its transportation
                                                      system can have for a company. In this section,              when determining sanctions. For example, in
routes, DESC was able to achieve a substan-           these benefits are categorized into five main                Nova Scotia a judge dismissed a case against a
tial reduction in insurance fees. In turn, the        areas that are most relevant to SMEs.                        pulp and paper mill for a small oil spill because
carriers, once they implemented these prac-
                                                                                                                   the company had an EMS in place that addressed
tices across their operations, were able to
negotiate a reduction in their own insurance.         Enhanced Efficiency and Lower Costs                          spill issues. The judge cited the company’s due
Accidental index was reduced from six acci -          EMS manuals and case studies point most fre-                 diligence, stating "the supervisor who found the
dents in 2001 to zero in 2004. Part of the            quently to the financial benefits of implementing            leak . . . knew the equipment, what to do to
evaluation tools used came from the
Responsible Care System of Mexico’s                   an environmental management system. Cost sav-                stop the leak and did so immediately. . . . He had
National Association of the Chemical Industry         ings are often linked with consuming fewer                   been instructed on what to do in the event of
(Asociación Nacional de la Industria                  resources and producing less waste, but savings              any oil spill and he did that." R. v. Stora Forest
Química—ANIQ)
                                                      can also accrue from operational efficiencies, a             Industries Ltd., [1993] N.S.J. No. 330 (N.S. Prov.
Source: Margarita Ferat Toscano, corporate environ-   higher level of management efficiency, reduced               Ct. Jun 23, 1993) Chapter 7 describes how gov-
mental manager, DESC, SA de CV, e-mail message
to Ignacio González, CEC, 4 october 2004.
                                                      liabilities and shorter permitting times because of          ernment policies encouraging EMS usage may
                                                      better relations with regulators and communities.            also affect penalty calculations.
                                                              Operational efficiency usually involves
                                                      replacing or renovating equipment and facilities,            Reductions in Resource Use, Waste and
                                                      as well as improving the production process                  Emissions
                                                      design and paying closer attention to all inputs             Many SMEs rate the success of their EMSs by
                                                      and outputs. Such changes can reduce inputs                  monitoring the resources used and the waste
                                                      (energy, water, etc.) or make operations more                minimized, both of which are closely related to
                                                      efficient, so that production is higher, faster or           cost savings. Implementing an EMS allows a
                                                      cheaper than before. Costs are compared pre-                 company to identify opportunities for improve-
                                                      and post-EMS implementation.                                 ment and to plan expenses. Key performance
                                                             Even small changes in operational efficiency          indicators include: the volume of raw materials,
                                                      can produce significant results. During its EMS              water and energy consumption, recycling rate,
                                                      identification process, one company highlighted              hazardous and nonhazardous waste generation
                                                      in the IFC case studies (Figure 3.1) noticed that            and the number and volume of releases. Organi-
                                                      one of its large machines had a serious oil leak.            zations use self-generated records, bills or data
                                                      The leak was quickly repaired with a $5 gasket.              from various utilities to measure consumption
                                                      This easy, inexpensive action cut the amount of              and waste pre- and post-EMS implementation.
                                                      oil consumed by the company by half, resulting                    Both large corporations and small and
                                                      in significant cost savings. In addition, the local          medium-size enterprises use EMSs to reduce
                                                      municipal authority reclassified the plant as no             resource and energy consumption, as well as




                                                      12   E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
the volume and toxicity of waste generation.        the United States, which was cited in the Nation-
                        Fourteen of 15 International Finance Corpora-       al Database on Environmental Management Sys-
                        tion case studies claim reduced waste, con-         tems study, designed its EMS without employee
                        sumption or toxicity as companies' main goals in    involvement, but then engaged employees in a
                        EMS design and implementation, as well as the       series of classes and meetings to introduce and
                        primary criteria for evaluating EMS usefulness.     reinforce EMS concepts. It also trained a dozen
                        Elsewhere, in a survey of 580 manufacturing         employees from the company to act as internal
Fourteen of 15          plants with more than 50 employees, Florida         auditors. By contrast, another company cited in
                        and Davison (2001) found that facilities with       the NDEMS study, a 350-person manufacturing
International Finance   EMSs resoundingly pointed to recycling and          plant, selected a wide range of employees, from
                        reductions in air emissions and solid waste and     managers to engineers to line operators, to
Corporation case        electricity use as evidence of facility-level       make up the team responsible for creating the
                        improvement.                                        EMS. The company considered employee
studies claim reduced                                                       engagement in the design process as important
waste, consumption      Regulatory Compliance
                        Another frequent indicator of a successful EMS
                                                                            as engagement in implementation.

or toxicity as com-     is achieving the goal of regulatory compliance.     Improved Relations with Customers
                        The criteria an organization selects to measure     An EMS can improve relations with customers.
panies’ main goals      improvement can vary widely and depends on          For an SME, improved relations usually means
                        the company’s compliance history and regulato-      larger purchasers in a dominant market position,
in EMS design and       ry burden. Management can use an EMS to             such as Ford and GM, which require their sup-
                        monitor the legal requirements and thereby plan     pliers to be ISO 14001-certified. Smaller compa-
implementation, as      expenses associated with permitting, reporting      nies, however, may also find that an EMS means
                        and monitoring to ensure compliance with the        wider appeal in a more local market. For exam-
well as the primary     law. Ideally reducing the frequency and severity    ple, Framboisière de l'Estrie, a berry farm in
                        of violations and the associated costs.             Quebec, was one of the first two farms with ISO
criteria for evaluat-         An EMS can also help a company to pre-        14001 certification in North America (see side-
                        pare for a more stringent application of environ-   bar). It markets its environmental improvements
ing EMS usefulness.     mental regulations by the government. For           and the positive economic benefits it has reaped
                        example, the IFC case studies include the           from ISO certification.
                        example of a manufacturer of office furniture
                        that eliminated methyl chloroform from its          The Benefits and Common Characteristics
                        cleaning and fastening processes and reduced        of Successful Environmental Management
                        the volume of emissions of volatile organic         The success of an organization’s EMS can be
                        compounds (VOCs) by converting to a powder-         evaluated by monitoring the organization’s
                        based coating system. These pollution preven-       progress toward meeting its environment-relat-
                        tion alternatives saved the company more than       ed objectives and targets. Understanding the
                        $1.1 million a year and gave the company a          common characteristics of a successful EMS will
                        return on its $1 million investment in less than    help to ensure that the conditions needed to
                        one year. This effort helped the company to         support successful EMS design and implementa-
                        comply more easily with increasingly stringent      tion are present.
                        environmental regulations and eliminated incin-
                        eration fees for solid and liquid hazardous         Designed with a Strong Business Case in Mind.
                        wastes (IFC 2004).                                  A successful EMS is developed with a strong
                                                                            business case in mind. Its purpose is to improve
                        Employee Involvement                                the value of the company through risk reduc-
                        Many companies recognize that the success of        tion, revenue enhancement and cost reduction.
                        an EMS depends on the participation of the full
                        spectrum of employees. Indeed, employee             Supported by Management and Commitment of
                        engagement is at the heart of the Total Quality     Resources. Unless the owner and upper man-
                        Management (TQM) process on which EMS               agement are committed to and supportive of the
                        principles depend. Different types of employees     EMS, it is extremely difficult to obtain the
                        have different insights into environmental per-     resources and cooperation needed to success-
                        formance and suggestions for improvements.          fully develop and implement an effective sys-
                        Proper implementation of an EMS requires            tem. The environmental policy, as endorsed and
                        employee involvement and, if successful, cre-       supported by management, defines the strate-
                        ates as a benefit a sense of responsibility and     gy of the organization and specifies the scope
                        accomplishment among the employees.                 and commitments of the EMS to employees,
                             A 90-person metal finishing company in         customers and those outside the company,




                        13   A NORTH AMERIC AN PERSPE CTIVE
such as local agencies, investors and communi-       of the EMS. A key element of any management
                                                   ty groups.                                           system is the opportunity it provides for learning
                                                                                                        from experience. Given the size, resources, and
                                                   Engaged Employees. When employees at all             variety of structures, as well as the obstacles
                                                   levels of an organization are engaged in an          faced by small and medium-size enterprises in
                                                   EMS, it is more likely to succeed. Under a well-     implementing environmental management sys-
Improving the Value of the Raspberry               designed EMS supported by management, indi-          tems, it is important that those systems be flexi-
Business                                           vidual employees understand their roles and          ble. Whenever possible, the goals and
Situated at Johnville, near Lennoxville,           responsibilities, receive adequate training and      complexity of an EMS should be set by the com-
Quebec, the Framboisière de l’Estrie stretches     information, and are aware of the potential envi-    pany itself. Those goals will necessarily be limit-
over 11 hectares. Each year the farm grows
and sells 43,000 kilograms of fruit and mar-       ronmental impacts of their jobs. Typically, when     ed by financial and economic considerations,
kets associated products such as syrup. As a       employees are engaged in such a program they         including the profitability requirements of the
result of going through the ISO process, the       enjoy a sense of ownership and possess the           organization.
farm did away with all pesticide use and
replaced fertilizers with compost, maintained
                                                   motivation to make a positive contribution to
water consumption while increasing produc-         the success of the program.                                                * * *
tion surface by 50 percent and reduced the
cardboard content of its boxes by 50 percent,
                                                   Integrated into Business. The most successful        With these potential benefits, why aren’t more
which reduced its purchase, transportation
and storage costs. Overall, its production         EMSs are not stand-alone projects or initiatives;    SMEs designing and implementing successful
costs decreased while yield increased.             they are part of the standard decision-making        EMSs? One reason is that, in most cases, the
                                                   process of a business. They also are integrated      driving forces are not strong enough to over-
                                                   into all aspects of a company’s activities, prod-    come the barriers. It is essential that those pro-
                                                   ucts and services. In the NDEMS study, all com-      moting an EMS to such enterprises understand
                                                   panies that had adopted EMSs asserted that they      the drivers and barriers faced by an SME. The
                                                   saw a business value in improving their environ-     driving forces or barriers that are most impor-
                                                   mental performance.                                  tant depend on the type of industry, the size of
                                                                                                        the business and its customers.
                                                   Clearly Defined Objectives and Targets. Success-
The Case of Salsa de La Laguna                     ful EMSs tend to set both abstract/overarching
In adopting an environmental management            and specific/measurable goals. An abstract/
system, employee engagement and buy-in             overarching goal may be "transparency," where-
can be particularly important when a compa -       as a specific/measurable goal may be "Have
ny has a recognized brand name. The
Guadalajara Environmental Management Pilot         Michael document the EMS design and imple-
(GEMP) study recounts the case of Salsa de         mentation process" or "Reduce air emissions by
La Laguna (SLL), a 30-person Mexican com -         35 percent by 2006." Abstract/overarching
pany that makes hot sauce and supplies one
of the largest tequila manufacturers in Jalisco
                                                   goals allow for creativity and problem solving,
with sangrita.                                     because managers and employees are not
     The company faced environmental issues        bound to follow certain codes. Specific and
associated with excessive noise, the dis -
charge of raw materials, generation of exces -
                                                   measurable goals ensure that the abstract is
sive waste, effluent discharges to a lake and      translated into the feasible and achievable. This
an excessive risk of fire. SLL developed a         duality also places smaller objectives in the con-
comprehensive EMS by mobilizing work               text of larger goals.
teams to analyze and respond to problems in
industrial hygiene, raw material use and con -
trol of wastes, effluent discharges and noise.     Continual Monitoring and Measurement. Moni-
Among the ideas that they, together with           toring and measurement are always cited in
management and a university consultant, had
were sorting solid waste into reusable and         EMS success stories, but companies go to wide-
recyclable bins, cleaning up work spaces,          ly different lengths to monitor and measure
improving the maintenance of company vehi-         their progress.
cles, reducing effluent discharges through
water conservation, reducing the use of sani -           After setting objectives and targets, a com-
tizing chemicals, requiring suppliers to use       pany should devise a means of monitoring and
strong containers in order to reduce waste         measurement, preferably in quantifiable terms.
and loss, and rinsing out drums of orange
juice to salvage concentrate. Some of these
                                                   Are changes being implemented? Are the cor-
measures resulted in savings of over               rect policies being pursued? Is the amount of
US$10,000 a year. This new environmental           waste being reduced, and, if so, by how much?
consciousness went beyond the factory.
                                                   How much money is being saved through waste
According to the report on the project, some
workers "began wearing T-Shirts describing         reduction? Are targets being met? Are more
their new environmental concerns, to speak         effective means of reducing waste available?
at local schools, and to participate in environ-   Should objectives and targets be revised? Ques-
mental cleanup activities in the community"
(World Bank 1998).                                 tions like these should be asked daily by any
                                                   company and not limited to the start-up period




                                                   14   ENVIRONMENTAL M ANAGE MENT SYSTE MS
5. DRIVERS AND BARRIERS TO EMS ADOPTION BY
                          SMALL AND MEDIUM-SIZE ENTERPRISES

                                riving forces are factors that create or        in an environmentally responsible way. The
                          D     change an organization’s environmental
                          performance by pushing it to utilize environ-
                                                                                Canadian Federation of Independent Business
                                                                                (CFIB) survey of SMEs revealed that respon-
                          mental management tools, including environ-           dents in the most regulated industries—that is,
                          mental management systems. The drivers are            those in the primary and agricultural sectors—
                          usually directly related to the benefits articulat-   were more likely to adopt a formal environmen-
                          ed in the case studies in Chapter 4: enhanced         tal management system. Businesses in these
                          efficiency and lower costs; reduced resource          sectors were also subject to higher levels of cus-
                          use, waste and emissions; regulatory compli-          tomer requests for EMSs (CFIB 2001).
                          ance; employee involvement and improved
                          relationships with customers. Other drivers           Driver - Customer Requirements
                          might be motivators such as building relation-        For a small and medium-size business, one tan-
                          ships with government agencies, achieving             gible value in creating and implementing an
                          faster approval of projects, seeking fewer            EMS is that such a step will meet the require-
                          inspections and less scrutiny, creating a good        ments of larger customers, or dominant buyers.
                          public image and responding to pressures from         Large multinational companies are increasingly
                          internal stakeholders within a company.               requiring their suppliers to adopt environmental
                                 Unlike large companies with a recognized       management systems—a development that
                          brand name and large public exposure, smaller         directly affects SMEs. By choosing not to do
                          businesses, especially suppliers to larger com-       business with firms that do not adhere to their
The owner of the          panies, are unlikely to implement an EMS as a         environmental policies, large multinational com-
                          way enhance their reputation with the public.         panies are able to greatly influence the environ-
business must believe     The owner of the business must believe that the       mental impacts of their smaller suppliers and
                          EMS will create real tangible value for the busi-     distributors. DaimlerChrysler, Ford, General
that the EMS will         ness. When a strong business case exists, the         Motors and Sony, for example, now require ISO
                          business owner’s active support for the design        14001 certification of their primary and second-
create real tangible      and implementation of the EMS is critical to          ary suppliers. Large companies impose these
value for the business.   help ensure its success.                              requirements for a variety of reasons. Among
                                                                                them are reduced risk, new European Union
                          Driver - Economic Factors                             regulations restricting substances in consumer
                          An EMS can, in many instances, create real tan-       products, direct financial savings, improved
                          gible value for a business in risk reduction, rev-    relations with their customers or regulators and
                          enue enhancement and cost reduction. A small          recognition of responsibility for their environ-
                          background survey conducted by the National           mental impacts.
                          Environmental Education and Training Founda-                An example of the effect large corpora-
                          tion (NEETF) in the preparation of its 2001           tions can have on their supply chain is illustrat-
                          report "Standardizing Excellence: Working with        ed by the Environmental Performance
                          Smaller Businesses to Implement Environmental         Agreement between the Canadian Automotive
                          Management Systems" found that the top five           Parts Manufacturers’ Association (APMA), Envi-
                          factors likely to drive EMS adoption in smaller       ronment Canada Ontario Region and Industry
                          enterprises were                                      Canada. The agreement, entered into in 2002,
                                                                                committed participating APMA member compa-
                          1. business benefits of an EMS                        nies to be ISO 14001–registered by December
                          2. tax breaks for EMS implementation                  2003 and to take action to reduce emissions of
                          3. customer EMS purchasing requirements               volatile organic compounds, carbon dioxide and
                          for suppliers                                         other substances. APMA members collectively
                          4. insurance benefits of an EMS                       account for over 90 percent of the $35 billion
                          5. a performance-based regulatory system.             automotive parts industry production in Canada.
                                                                                This agreement was a response to the supply chain
                               In heavily regulated sectors, an EMS may         requirements of DaimlerChrysler, Ford Motor
                          be a way to demonstrate to regulators, lenders,       Company and General Motors. Specific targets
                          insurers and buyers that a company is managed         and timelines for this initiative are an aggregate




                          15   A NORTH AMERIC AN PERSPE CTIV E
Mexico’s National Association of the Chemical Industry (Asociación Nacional de
la Industria Química—ANIQ) was the first association to design its Responsible
Care program as an environmental health and safety management system
(Sistema de Administración de Responsabilidad Integral—SARI).
                                                  reduction of 20 percent in VOCs and 3 percent                 for becoming a member of ANIQ. Members must
                                                  in carbon dioxide and CEPA toxic substance                    commit themselves is to actively participating in
                                                  substances (where applicable) by 2007.7                       assistance activities designed to support the
                                                        A recent pilot project by the World Envi-               Responsible Care program in member SMEs.
                                                  ronment Center (WEC) illustrates this trend. The                    Responsible Care had a strong impact on
                                                  WEC is a not-for-profit organization composed                 the decision by the National Association of
                                                  of many large multinational corporations. The                 Chemical Distributors (NACD) to develop an
                                                  Center’s Supply Chain Management Partnership                  environmental code of its own (the NACD has
                                                  promotes the adoption of improved environ-                    members in Canada and the United States, and
                                                  mental management techiniques and cleaner                     many of its members are small businesses). The
                                                  production programs among companies that                      NACD code is based on Responsible Care, but
                                                  supply WEC member companies. The WEC is                       is stronger in several respects; it requires third-
                                                  implementing pilot projects with multinationals               party verification of members’ performance, as
                                                  and a select number of their suppliers in Mexico,             well as health, safety, and security, and has a
                                                  Brazil and China (where the project is in the                 history of suspending and terminating members
                                                  planning stage). In Mexico, the project involves              for noncompliance (Nash 2000).
                                                  Janssen-Cilag, an operating subsidiary of John-                     The Environmental Commitment and
                                                  son & Johnson that produces drugs for clients                 Responsibility program of the Canadian Electric-
                                                  around the world, and Alcoa Fujikur, whose                    ity Association (CEA), which counts small and
                                                  lines of business include automotive and elec-                medium-size businesses among its members,
                                                  tronic distribution systems and fiber-optic cable.            stipulates that adoption of an ISO 14001–con-
                                                                                                                sistent EMS is a condition of membership.
                                                  Driver - Trade Association Requirements                       Under the Environmental Commitment and
                                                  Some trade associations require their members                 Responsibility program, a verification team visits
                                                  to have an environmental management system                    a selected number of utilities each year to deter-
The Importance of the Business Owner              in place or to adhere to environmental codes of               mine whether the EMS implemented satisfies
For small and medium-size enterprises, a cen-     conduct. For example, national chemical associ-               the program’s requirements.
tral factor in the implementation of an envi-
ronmental management system is the                ations in 52 countries run Responsible Care®                        For SMEs, market forces are particularly
leadership of the top manager in pushing for      programs. Under Responsible Care, member                      important. This is especially true in Mexico,
continual improvement. Observers have             companies must commit to adopting a set of                    which has a large, informal economy and whose
noted that a commitment to achieving envi-
ronmental improvements is a far bigger factor     guiding principles, codes, guidelines and check-              smaller businesses may be subject to fewer reg-
in achieving environment results than merely      lists on health, safety and environmental matters,            ulatory pressures. A recent Inter-American
having an EMS in place; an EMS just makes a       and to developing indicators and verification                 Development Bank study of ISO 9000, and to a
company be able to achieve these improve-
ments. In fact, a Canadian Federation of Inde-
                                                  procedures. They must communicate their "good                 lesser degree ISO 14001, in certain areas of
pendent Business (CFIB) survey found that         faith efforts" to implement the codes to employ-              Latin America, including Nuevo León in Mexico,
for 87 percent of respondents the personal        ees and stakeholders.8                                        found that a key determinant of the quality of
views of owners were the primary motivation
                                                         Mexico’s National Association of the                   the environmental management system was the
for improved environmental performance
(CFIB 2001).                                      Chemical Industry (Asociacion Nacional de la                  extent to which management demanded the
      The Guadalajara Environmental Manage-       Industria Quimica—ANIQ) was the first associa-                system (IADB 2004). However, despite these
ment Pilot (GEMP) and Proyecto Adminis-           tion to design its Responsible Care program as                market forces, for most SMEs the barriers to
tración Ambiental Monterrey (PAAM) studies
highlight the importance of manager support       an environmental health and safety management                 EMS adoption outweigh the drivers.
for employee involvement in the EMS process.      system (Sistema de Administracion de Respons-
Those managers who enthusiastically adopted       abilidad Integral—SARI). It incorporates elements             Barriers to EMS Adoption
EMS concepts and who worked with their
employees achieved successful EMS imple-          of ISO 14001 and fulfills other requirements of               Barriers are factors that hamper and can even
mentation during the study time period,           different known management systems related to                 bring to an end the design, implementation and
whereas those managers who did not with           environmental, health and safety issues. Adoption             operation of an environmental management sys-
their employees failed. A manager who sees
an economic benefit in EMS implementation
                                                  of the Responsible Care program is a condition                tem. Even when driving forces exist, SMEs may
and actively supports its design and develop-                                                                   face imposing barriers when designing and
                                                  7. B. Brad Cummings, manager, Pollution Prevention and
ment is a critical factor in EMS implementation
                                                  Innovative Technologies, Environment Canada Ontario Region,
                                                                                                                implementing an EMS that larger companies are
(Lexington Group 2002).
                                                  e-mail message to Tim Whitehouse, CEC, January 28, 2005.      less likely to face. A Lack of knowledge about
                                                  8. See <http://www.responsiblecare.org>.                      and awareness of environmental management




                                                  16    ENVIRONMENTAL MANAGE MENT SYSTEMS
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5200 ems report-en

  • 1. Successful Practices of Environmental Management Systems in Small and Medium-Size Enterprises A North American Perspective Commission for Environmental Cooperation
  • 2. ACKNOWLEDGMENTS This report was prepared by Tim Whitehouse, Head of the Law and Peer reviewers also provided extremely valuable comments Policy Program of the Secretariat of the Commission for and ideas during the development of this report. They provided Environmental Cooperation (CEC). Morgan Rider, member of the many insights into the issues faced by small and medium-size busi- environmental consulting firm Ecology and Environment, Jerry nesses in implementing environmental management systems and Speir, an attorney practicing in New Orleans, Louisiana, and Dixon into the types of resources available to help these businesses Thompson, professor of environmental science at the University of improve their environmental performance. These reviewers were Calgary’s School of Environmental Design assisted in the design, Leonardo J. Cárdenas, Principal Consultores en Calidad Ambiental research and writing of this report. SA de CV; Raymond P. Côté, professor, School for Resource and The Secretariat is grateful to Environment Canada, Mexico’s Environmental Studies, Dalhousie University; Margarita Ferat Toscano, Federal Attorney for Environmental Protection ( Procuraduría environmental corporate manager, DESC SA de CV; Louise Millette, Federal de Protección al Ambiente) and the US Environmental director, Department of Civil, Geological and Mining Engineering, Protection Agency for their comments on this report. The views École Polytechnique de Montréal; David Ronald, executive director, expressed in this report are not necessarily those of the govern- Multistate Working Group; and Richard P. Wells, president, ments of Canada, Mexico or the United States. Lexington Group. The Commission for Environmental Cooperation (CEC) was established under the Commission for Environmental Cooperation North American Agreement on Environmental Cooperation (NAAEC) to address envi- 393, rue St-Jacques Ouest, Bureau 200 ronmental issues in North America from a continental perspective, with a pa rt i c u- Montréal (Québec) Canada H2Y 1N9 lar focus on those arising in the context of liberalized trade. E-mail: info@cec.org http://www.cec.org This publication was prepared by the Secretariat of the CEC. The views contained herein do not necessarily reflect the views of the CEC, or the governments of Canada, Mexico or the United States of America. ISBN: 2-923358-29-5 Reproduction of this document in whole or in part and in any form for educational or © Commission for Environmental Cooperation, 2005 nonprofit purposes may be made without special permission from the CEC Secretariat, provided acknowledgement of the source is made. The CEC would Legal Deposit-Bibliothèque nationale du Québec, 2005 appreciate receiving a copy of any publication or material that uses this document as Legal Deposit-Bibliothèque nationale du Canada, 2005 a source. Disponible en español - Disponible en français Design: Associés libres, Montreal December 2005 Printed in Canada on paper containing 100% post- consumer waste fiber.
  • 3. CONTENTS 1. Introduction 2 2. Defining Small and Medium-Size Enterprises 4 and Environmental Management Systems 3. Are Environmental Management Systems Effective? 9 4. The Benefits and Common Characteristics of Successful 12 Environmental Management Systems 5. Drivers and Barriers to EMS Adoption by Small 15 and Medium-Size Enterprises 6. Technical Assistance and Outreach 18 7. Incentive Programs and Policies 24 8. Future Directions 27 Appendix A. Useful Web Sites 29 Appendix B. 10 Elements of an Environmental 30 Management System References 31
  • 4. 1. INTRODUCTION his report examines the use of environmental 1. designed with a strong business case in mind T management systems (EMSs) in small and medium-size enterprises (SMEs) in Canada, 2. managerial support and commitment of resources Mexico and the United States. In doing so, it pro- 3. engaged employees vides a North American perspective on success- 4. integrated into business ful practices and some of the issues faced by 5. clearly defined objectives and targets SMEs in developing and implementing these sys- 6. continual monitoring and measurement. tems. It also offers some suggestions for contin- ued cooperation between the governments of Not all EMSs, however, are effective in Canada, Mexico and the United States on promot- improving environmental performance. Most ing EMSs. SMEs face few incentives and many difficulties Over the past decade, the three govern- in implementing environmental management ments have promoted the use of EMSs to help systems. The owner of a business must believe companies improve their environmental per- that an EMS will create real tangible value for formance and move beyond compliance with the business. Yet most SMEs do not know what the law. The Commission for Environmental an EMS is and, if they do, how it could benefit Cooperation (CEC) has served as a forum in their business. Even if they are familiar with the which the three governments could share their concept of an EMS, many smaller businesses experiences, practices, and successes on the use lack the technical expertise and resources of EMSs in North America. In June 2000, for needed to develop and implement one. example, the CEC published Improving Envi- Although business needs may ultimately ronmental Performance and Compliance: 10 determine whether an SME implements an EMS, Elements of Effective Environmental Manage- government or private sector technical assistance ment Systems, which described those elements and outreach efforts are often crucial to provid- that the three governments agreed were impor- ing the conditions under which businesses—par- tant to address in implementing EMSs (CEC ticularly small and micro-businesses—are likely to 2000). The CEC has also encouraged a North implement a successful EMS. Continued cooper- American dialogue on the use of environmental ation among the governments of Canada, Mexico management systems through its support of and the United States could help improve the and participation in numerous workshops and delivery of sector-specific information and techni- forums, including most recently those of the cal assistance and specific advice on EMS North American Pollution Prevention Partner- methodologies to SMEs. ship, Mexico’s Pollution Prevention Roundtable, the Auditing Roundtable and the Canadian Organization of This Report Environmental Auditing Association. The chapters that follow describe a North In recent years, the private sector has devel- American perspective on the use of environ- oped various types of EMSs for identifying and mental management systems in small and medi- managing the impacts that commercial, industrial um-size enterprises. The definitions of an EMS and service operations have on the environment. and a SME in Chapter 2 are followed by a closer Although the use of EMSs is becoming more look in Chapter 3 at the effectiveness of envi- common among larger companies, their use by ronmental management systems in improving small and medium-size enterprises is less com- environmental performance. Chapters 4 and 5 mon. then look at the benefits and characteristics of a A successful EMS can enhance efficiency successful EMS and the drivers and barriers to and lower costs, reduce resource use and waste, EMS adoption by small and medium-size busi- help to ensure compliance with regulatory nesses. Chapters 6 and 7 review the technical requirements, encourage employee involvement assistance and outreach, and the incentive pro- in environmental performance and improve rela- grams and policies in the three countries. Chap- tions with customers. In examining a variety of ter 8 concludes by examining areas for future experiences in North America, this report identi- cooperation by the three governments on EMS fies six common characteristics of successful EMSs promotion in North America. The two appen- adopted by small and medium-size enterprises: dices to the report provide general information 2 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
  • 5. on environmental management systems. Appendix A lists some useful web sites in addi- tion to those found as reference to this text, and Appendix B presents the CEC’s "10 Elements of Effective Environmental Management Systems." With the growing integration of the North American economy under the North American Free Trade Agreement (NAFTA), the CEC is in a unique position to step back and examine the development of EMS policies and programs in all three countries. Such an examination can help those promoting environmental management systems in Canada, Mexico and the United States to learn from the experiences of the other countries and can help to inform and stimulate discussion and critical comment among those assisting small and medium-size enterprises with environmental issues. 3 A NORTH AMERICAN PER SPECTIVE
  • 6. 2. DEFINING SMALL AND MEDIUM-SIZE ENTERPRISES AND ENVIRONMENTAL MANAGEMENT SYSTEMS mall and medium-size enterprises in North percent of their gross domestic product (GDP) S America vary widely in their impacts on the environment. An environmental management and over half of their private sector employment. In the manufacturing sector, SMEs generate 55 system offers the methodology a company percent of manufacturing employment in Canada, needs to identify and implement ways in which 66 percent in Mexico and 41 percent in the to improve the environment both inside and out- United States (OECD 2002). side a plant or business, from mere good house- Although most SMEs serve local markets, keeping steps to strategies to prevent pollution. they are increasingly operating as part of a glob- This chapter examines the various defini- al marketplace, purchasing products produced tions of small and medium-size enterprises and abroad, supplying multinational companies and some of the different types of environmental selling directly to overseas buyers. In North Small and Medium-Size Enterprises? management systems in the three countries. America, SMEs play an important role in the The threshold of 500 employees guides the Although the definition of a small and medium- market-driven coordination of production across classification of small and medium-size enter- size enterprise varies from country to country, it the US-Mexico and US-Canada borders, espe- prises (SMEs) in Canada, Mexico and the United States. Environment Canada typically is useful to examine SMEs as a general category. cially in sectors such as automobile, telecommu- classifies enterprises with less than C$50 mil - These kinds of enterprises generally have fewer nications equipment, computer, electronic lion in annual revenues that are not wholly resources to address their environmental impacts products and textiles and apparel. owned subsidiaries as follows: less than 5 employees, microenterprise; 5–49 employ- and are thought to be less likely to implement SMEs face widely differing environmental ees, small enterprise; 50–499 employees, EMSs than larger companies. They also do not, issues based on the economic sector, employee medium-size enterprise (Environment by most definitions, have a parent company on base and jurisdiction in which they operate. The Canada 2003). The medium-size category is not com - which to rely for assistance. Despite these limi- requirements, demands, pressures and issues monly used in the United States, and the US tations, SMEs can use the basic methods of they face will more often resemble those faced Environmental Protection Agency considers a implementing an EMS as described in this chap- by companies in their own economic sector, small business for research grant programs to ter to integrate environmental planning into their regardless of size, than those in other sectors. be a for-profit organization with no more than 500 employees that is not dominant in the everyday business practices. In addition, within the SME category differ- field of operation. For Performance Track ences often exist in the technical capabilities of Purposes (see Chapter 7), a small business is What are Small and Medium-Size small and medium-size businesses, with medi- defined as a facility with fewer than 50 employ- ees. These facilities may be part of larger Enterprises? um-size business much more likely to have organizations. The US Small Business SMEs are found in the largest and most dynamic engineering expertise than small enterprises, Administration has devised sector-specific defi- sectors of the North American economy, rang- especially related to energy efficiency and con- nitions with both employee and revenue limits. See <http://es.epa.gov/ncer/sbir/ ing from those that are pollution-intensive and servation. 2005SBIRfactsheet.pdf> and resource-intensive, such as manufacturing and SMEs, even those in the retail sector, can <http://www.sba.gov/size/>. natural resource extraction, to those that are have significant impacts on the environment, In Mexico, Profepa follows a classification (by number of employees) established by the more environmentally benign, such as retail. They including those from nonregulated activities Secretary of Economy in 1999: often face unique environmental challenges that such as resource consumption, packaging and Industrial CommercialService are related to their size and their place in the methods of hazardous and nonhazardous waste Micro 0–30 0–5 0–20 economy. (See Table 2.1) disposal. According to Environment Canada Small 31–100 6–20 21–50 The economic importance of SMEs in (2003), of the 2 million Canadian SMEs, the Medium 101–500 21–100 51–100 North America is significant. Over 98 percent of 400,000 most pollution-intensive are in the agri- businesses in Canada, Mexico and the United culture, primary and manufacturing sectors.1 A Mexico’s National Institute of Statistics, Geography and Informatics Instituto Nacional States are small and medium-size enterprises. de Estadística Geografía e Informática— SMEs are found in all the economic sectors of 1. The primary sector includes activities such as fisheries, mining, INEGI) has more specific classifications. the three countries, producing approximately 40 forestry and oil and gas extraction. Table 2.1 Distribution of Employment in Manufacturing by Size Class Country 0–9 10–49 50–99 100–499 500+ Total Canada 4.1 17.8 8.8 24.2 45.0 100 Mexico 18.9 12.0 7.5 27.6 34.0 100 United States 3.6 4.1 16.0 17.4 58.9 100 Source: OECD 2002. 4 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
  • 7. study prepared for the Organization for Economic with its "Pollution Prevention Pays" program, Co-operation and Development (OECD) found and Dow, with its "Waste Reduction Always that SMEs in the United States are significant Pays" (WRAP) program. In the 1980s, EMS pro- contributors of pollution in three branches of grams largely focused on due diligence and manufacturing: chemicals, primary metals and compliance with laws and regulations as well as building materials (e.g., stone, clay and glass). ways to cut costs in disposing of wastes and The largest impacts from these SMEs were on treating effluents. Also in the 1980s, trade asso- biological oxygen demand (BOD) in water and ciations began to develop codes of environ- suspended particulates in air, followed by the mental practices, which approximated the release of toxic chemicals (OECD 2002). But definitions of environmental management sys- those statistics for the United States were devel- tems (Pacific Institute for Studies in Develop- oped in a study done specifically for OECD; ment, Environment, and Security 2000). generally, "comprehensive pollution or resource consumption statistics for SMEs do not exist, EMS Models making it difficult to determine their contribution Today, EMSs can range in complexity from sim- Total Quality Management to environmental degradation" (OECD 2002). ple reminders of regulatory deadlines at a single Most systematic approaches to addressing facility to an elaborate, Internet-based, enter- performance issues derive from the work of What Is an Environmental Management prise-wide performance management system W. Edward Deming, the US statistician who System? that tracks regulatory requirements, assigns is credited with dramatically improving the performance of Japanese industry after World An environmental management system is a tool tasks, controls documentation and records, pro- War II with a system that has come to be used by a company to identify measure and vides training, and shares information across mul- known as Total Quality Management (TQM). manage the effects of its activities on the envi- tiple operations and facilities around the world. Deming also popularized the plan–do– check–act cycle that is at the root of all such ronment. An EMS sets out the company’s goals EMSs are most effective when they are systems: identify and analyze the problem for environmental performance and a plan for part of normal business activities rather than (plan), develop and implement solutions (do), achieving those goals. Ideally, company man- treated as separate programs or initiatives. evaluate and measure the results (check), and agers will set goals in areas such as compliance Although businesses typically have many ele- fix the problems identified and incorporate the lessons learned into a feedback loop that with environmental laws, minimization of risks ments of an EMS already in place, the EMS pro- begins the process anew (act). The feedback to human health and the environment, use of vides a systematic way to integrate those efforts loop involves all personnel and elements of an natural resources, and prevention and reduction and direct them toward company-established organization and runs counter to traditional top-down "management by objective" of pollution. goals. The significant range and variations of approaches. Environmental management sys- The evolution of EMSs in North America EMSs can be attributed to the differences tems turn the TQM process to a specific con- can be traced to the 1970s and the pollution among organizations in size, activities, impacts, cern for reducing environmental impacts. prevention programs of companies such as 3M, regulatory requirements, corporate culture and Source: Welch 1998. Figure 2.1 BC Hydro’s Environmental Management System Environmental Responsibility Policy Management Review Planning • Identifying aspects, impacts and operational controls EMS Checking and Corrective Action • Indentifying legal and other • Monitoring and measuring requirements • Process improvement • Meeting objectives, targets • Records and environmental programs • EMS compliance audits Implementing and Operation • Defining training needs • Implementing training • Internal communication and reporting • External communication Source: Industry Canada, • Document control <http://www.strategis.ic.gc.ca/epic/internet/ • Contractors and suppliers incsr-rse.nsf/en/rs00122e.html>. 5 A NOR TH AMERICAN PER SPECTIVE
  • 8. policy commitments. Figure 2.1 depicts the certification by accredited certificate bodies.2 EMS of BC (British Columbia) Hydro and is rep- The European Office of Crafts, Trades and resentative of the structure of many EMSs. Small and Medium-Sized Enterprises for Stan- dardisation (Le Bureau Européen de l’Artisant, The International Organization for et des Petites et Moyennes Enterprises pour la Standardization (ISO) 14001 Normalisation), better known by its acronym The most widely recognized model for an EMS NORMAPME, has formally asked the ISO to is the International Organization for Standard- "explore alternative ways to use the environ- ization (ISO) 14001 standard. This standard, mental management system standard ISO 14001 which is applicable to organizations of all types that are in line with their members’ limitations." and sizes, is based on five components: NORMAPME seeks changes that might include allowing an incremental implementation of ISO 1. An environmental policy that commits the 14001 or allowing organizations to be certified organization to "prevention of pollution," "con- in batches, sharing procedures and administra- tinual improvement" and compliance with "rele- tive costs. The ongoing revisions of ISO 14004 vant environmental legislation and regulations." are intended to simplify EMS requirements for 2. Planning to implement the environmental SMEs in order to facilitate implementation. ISO, policy, which entails identifying all of an organi- through its Sub-Committee 1 of Technical Com- zation’s interactions (activities, products or serv- mittee 207, has formed an ad hoc group to study ices) with the environment (its "environmental EMS penetration among small businesses, and a aspects") and designating the "significant" report is expected in September 2005.3 aspects and setting quantifiable objectives and targets for addressing those significant aspects. The Eco-Management and Audit Scheme 3. Implementation and operation, which Many European countries require large manufac- requires an organization to ensure the availabili- turing facilities to implement the Eco-Management ISO 14001 Trends in North America ty of resources, define roles and responsibilities, and Audit Scheme (EMAS). The components of As of December 2003, the breakdown of develop documented procedures, emergency EMAS are similar to those of ISO 14001. However, North American certifications for ISO 14001 preparedness plans and ensure employee com- EMAS has two significant additions: a baseline was Canada, 1,274; Mexico, 406; and the United States, 3,553 By contrast, in 1998 the petency, training and awareness. environmental assessment and a public environ- breakdown was Canada, 104; Mexico, 39; 4. Checking and corrective action to measure mental performance report. Many companies and the United States 291. See and track the performance of the system against outside Europe have also chosen to implement <http://www.iso.org/iso/en/iso9000- 14000/pdf/survey2003.pdf>. No specific its own goals and to evaluate compliance with the EMAS system or variations. numbers exist for SMEs, which are more the relevant laws and regulations. The organi- likely to use third-party registrars and zation must also identify, investigate and correct The CEC’s "10 Elements of Effective Environ- therefore are less likely to be reported any nonconformities. The organization must mental Management Systems" in the ISO system. ensure that internal audits are conducted. In June 2000, the Commission for Environmen- 5. Review of the EMS by top management "to tal Cooperation published the "10 Elements of ensure its continuing suitability, adequacy, and Effective Environmental Management Systems" effectiveness." (CEC 2000). The "10 elements" were negotiated by Canada, Mexico and the United States just The ISO standard focuses on conformance after the ISO 14001 standards were published with established policies, plans and procedures, and served as the first general policy statement but it does not specify requirements for environ- by the three governments on what they mental performance beyond compliance with the believed were important features of an EMS. relevant legislation. Organizations are, however, The "10 elements" are generic in nature and not free to set goals that exceed compliance specifically geared toward small and medium- requirements. size enterprises. Notably, they place greater Companies implementing ISO 14001 may emphasis on compliance with environmental choose to have their EMS certified. They can seek regulations than the ISO 14001 standard. Like third party certification from either accredited the ISO standard, the "10 elements" state that a certificate bodies (those recognized by a national company’s environmental policy should include accreditation body) or no accredited bodies. Most a provision for compliance with environmental firms seeking certification employ accredited requirements. But the "10 elements" go beyond bodies; these may be perceived on the market as the ISO in stating that an EMS should establish having greater credibility, although a firm that implements ISO 14001 solely for internal man- 2. For more on ISO certification, see <http://www. iso.org/iso/en/ agement purposes (without expectation of ben- iso9000-14000/basics/general/ basics_5.html>. efits from regulators, customers or public 3. See <http://www.iso.org/iso/en/CatalogueDetailPage. perception) may choose not to seek third party CatalogueDetail?CSNUMBER=31808>. 6 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
  • 9. objectives and targets for achieving and main- ples tend to be those tailored to a specific taining compliance with environmental require- industry and designed with input from the ments and a commitment to continuous industry itself. For example, the Texas Commis- improvement in environmental performance sion on Environmental Quality (TCEQ) developed (see Appendix B for the CEC’s "10 elements"). a sample EMS for small businesses in the metal finishing industry. (See Table 2.2) The EMS for A Sample EMS from the Metal Finishing the fictitious company, Papa Plating, covers all Industry on-site operations, including metal finishing and Various sample EMSs are available for small and processing activities, groundskeeping, offices medium-size enterprises. The most useful sam- and waste disposal. Table 2.2 Selected Aspects of Sample EMS Addressing Water Usage Form 7: Environmental Management Action Plans Significant Environmental Aspects Water Use Goal Reduce the amount of water purchased by 50% Action Plan Analyze how water is used and what can be done to minimize water use Consider different potential rinsing methods Review Cycle Willie Scott will review every 6 months Form 8: EMS Work Instructions Significant Environmental Associated Job Work Instructions Aspects Functions Needed Responsible Person Yes – employees should Parts Rinsing monitor the drip time over Plating supervisor the various rinse tanks and withdraw the parts at the proper speed Water Use Yes – employees should rack parts to minimize Parts Racking solution dripping on other Plating supervisor parts Form 9: Alternatives Identification — Significant Environmental Aspect: Water Use Activity Current Practice Potential Alternatives Rinsing methods Dip rinsing Try spray rinses in the various processes to try to improve rinsing performance and decrease water consumption Water flow Rinse water is being Research the use of conductivity meters flowed at a high rate and/or flow restrictions during production Treatment Currently chemically treated Consider the use of reverse osmosis and/or ion and discharged to waste- exchange after the initial treatment and reuse water treatment facilities the treated effluent back in our process Rinse tank None Consider the use of air agitation in the rinse tanks to improve agitation the rinsing process Source: TCEQ 7 A NOR TH AMERICAN PER SPECTIVE
  • 10. Papa Plating’s EMS contains elements of ISO 14001 and the CEC’s "10 elements." The EMS provides a sample action plan on water use, energy use, sludge generation and dispos- al, metal use and use of natural resources, organic emissions from a degreaser and human exposure to toxic materials and chromium emis- sions. A look at the selected portions of an EMS regarding water aspects of the Papa Platings EMS usefully illustrates some of the specific ele- ments of an EMS. Papa Plating’s system is just one example of how to create an EMS. An environmental management system can be designed to address the needs of any size organization. Standards groups, trade associations and gov- ernments have all designed different types of environmental management systems and pro- grams to help businesses improve environmen- tal performance by integrating environmental planning into everyday business processes. 8 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
  • 11. 3.ARE ENVIRONMENTAL MANAGEMENT SYSTEMS EFFECTIVE? ecent studies indicate that not all environ- and assistance from their parent organizations, R mental management systems lead to improved environmental or business perform- but they occur in privately held and govern- ment facilities as well." The NDEMS study is ance. However, several projects and numerous inconclusive on the financial benefits of an case studies of successful EMS practices in EMS, but notes that benefits were "moderately small and medium-size enterprises support the impressive" for the facilities that realized them. proposition that an effectively designed EMS Thirty-two facilities reported quantified mone- can, under the right circumstances, significantly tary benefits from EMS adoption; the average help a company improve its environmental per- net benefit for those reporting a benefit through formance and bottom line. Because not all the first three years was $90,320. (NDEMS EMSs produce positive benefits, it is important 2003) to understand the potential benefits of an EMS, One study completed by the University of the common characteristics of successful EMSs, Sussex in July 2000 compared EMS use in EMAS the drivers and barriers to EMS implementation, and ISO systems in 280 European companies at and the programs available to help SMEs 430 production sites and found no statistically improve their performance. These subjects are significant relationship between the adoption of covered in the chapters that follow. a formal EMS and improved environmental per- formance. The companies included 9 computer Empirical Studies of EMSs companies, 58 electric power generators, 26 fer- Empirical studies of the performance of EMSs tilizer manufacturers, 90 pulp and paper produc- have only recently begun to emerge. One of the ers, 46 printers and 45 textile finishers.4 only studies in North America was conducted in Another study of electronic firms observed An effectively the United States by the University of North that firms that adopted ISO 14001 were able to Carolina and the Environmental Law Institute catch up to industry best practices, especially if designed EMS can, between 1997 and 2002. The National Database they produced significant toxic emissions on Environmental Management Systems (Russo 2000). A study conducted in the auto- under the right (NDEMS) study examined environmental per- motive supply sector before Ford and General circumstances, formance data at 83 facilities over a five-year period. Ultimately, 30 facilities completed all five Motors required their suppliers to be ISO-certi- fied found minimal reductions after ISO 14001 significantly help a years of the study. The participating facilities adoption. In terms of toxic releases and compli- ranged from large, publicly traded major manu- ance with regulatory requirements, environ- company to improve facturers and electric utilities to small businesses mental performance was about the same in such as auto parts suppliers and electroplaters facilities that had adopted EMSs under ISO its environmental and government organizations, including military 14001 and those that had not (Matthews 2001). bases and municipal water treatment plants. performance and Approximately 70 percent of the organizations Projects and Case Studies participating in the NDEMS study were part of a Although little empirical work exists on the bottom line larger business or government organization. impacts of EMS adoption, the literature and The final report of the study concluded case studies contain valuable information on that evidence from the pilot facilities "suggests how companies have used EMSs to improve that the introduction of an EMS can be expect- environmental and business performance. ed to be at least somewhat beneficial to the The US Environmental Protection environmental performance of most facilities, as Agency’s web site includes a case study index well as to their operating and management effi- with links to EMS success stories, several of ciencies, and in some cases to their regulatory them on SMEs.5 The EPA case studies generally compliance patterns. These results are more include an introduction to the facility, an likely for facilities that are subsidiaries of pub- overview of the planning and implementation of licly traded corporations, owing to their greater the EMS, a list of the benefits achieved, and a access to management capabilities, resources, description of the lessons learned. One case study, for example, explains how the Mott’s 4. See <http://www.environmental-performance.org/analysis/index.php>. Aspers plant, an apple juice and apple sauce 5. See <http://www.epa.gov/ems/studies/index.htm>. plant with 378 full-time employees in Pennsyl- 9 A NORTH AMERICAN PER SPECTIVE
  • 12. vania, implemented a EMS that resulted in the In this project, 11 large companies in Guadala- production of less solid waste, reduced water jara, Mexico, signed a voluntary agreement with usage, increased recycling, savings on energy Mexico’s Ministry of Environment, Natural usage and wastewater treatment costs.6 Resources and Fisheries (Secretaría de Medio The Manual for Implementing EMS in Ambiente, Recursos Naturales y Pesca—Semar- SME, issued by the International Finance Cor- nap), now known as the Ministry of Environ- poration (IFC), also includes 15 case studies ment and Natural Resources (Secretaría de from facilities throughout the world, including Medio Ambiente y Recursos Naturales—Semar- the United States, on the actual benefits real- nat), to mentor small suppliers in implementing ized by small and medium-size businesses that EMSs. Within three months of completing the have implemented EMSs (IFC 2004). Some formal EMS training, over 80 percent of the 20 summaries of selected case studies from the IFC participating companies in the GEMP study had manual appear in Table 3.1. reduced their environmental releases, nearly 70 In Mexico, several projects have been percent had improved their work environment, undertaken to provide SMEs with technical and over 50 percent had improved their eco- assistance in implementing environmental man- nomic performance. agement systems. The Guadalajara Environ- Slightly less than 50 percent reported mental Management Pilot (GEMP), financed by improvements in waste handling, materials and the World Bank, studied the effects of EMS use energy efficiency, and compliance. The study in small and medium-size enterprises in Mexico. concludes that "gains from good housekeeping are potentially very large in the case of SMEs, 6. See <http://www.epa.gov/ems/studies/mott.htm>. and … an EMS provides a means to capture Table 3.1 Selected EMS in SME Case Studies, Worldwide Company Environmental Benefit Cost Savings Leff-Marvins Cleaners Inc. Replaced its old equipment with new system to The company realized a net savings of recycle PERC (perchloroethylene). Eliminated US$1,400 per month with the new system. most VOC (volatile organic compound) emis - sions and also reduced purchase of PERC from 200 gallons per month to 40 gallons per month. Reduced hazardous waste stream from over 1,900 gallons of spent PERC per year to just 35 gallons of still residues per month. Company A Introduced more efficient ways of handling Waste elimination bills were cut by 55 percent. cardboard. Reduced its waste by 577 tons in Saved staff time. the first year. Mounstevens Ltd., a manufactur- Increased staff awareness and introduced care- Expected benefits include cutting waste bills in ing and retail baker ful separation of waste. half and saving US$8,800 and 26 tons of waste. Company B Instituted a facility-wide municipal waste recy- Reduced disposal costs and gaenerated enough cling program, including metal, cardboard, revenue from marketing the recyclables to fund paper, wood, plastic and glass. More than 50 the program’s operating expenses, including wages percent of the municipal waste generated by and benefits, equipment operation and mainte - the company is now recycled. nance, utility costs and program improvements. Jamestown Paint Company Reduced its use of toluol by 95 percent and Information not available. xylol by 74 percent by developing water-based products to replace solvent-based coatings. A manufacturer of power steering Installed a green sand recycling system in its Reduction in the purchase of sand from 4 mil- gears, engine timing devices and foundry that puts recovered sand directly back lion pounds of sand per year to only 80,000 power transmission boxes into the processing lines, recovering about 95 pounds per year, saving on sand purchase and percent of silica sand. disposal costs. 10 ENVIRONMENTAL M ANAGEMENT SYSTE MS
  • 13. these gains very quickly." The project’s prelimi- nary findings indicate the following: s The ISO 14001 EMS model can be applied by SMEs without any modifications, with the exception of documentation. s Although the ISO 14001 EMS model is appro- priate for SMEs, most SMEs require substantial implementation support, particularly in the areas of simplified formats, discrete mile- stones, management systems thinking and Within three months staff assistance. of completing the s The business culture of a firm is probably a more important factor than size in determin- formal EMS training, ing whether it can implement an EMS (World Bank 1998). over 80 percent of Because the GEMP study was undertaken in the the 20 participating early stages of EMS implementation, the longer- term economic and environmental affects of companies in the EMS implementation have not been analyzed. In another project, Proyecto Administación GEMP study had Ambiental Monterrey (PAAM), undertaken in reduced their Monterrey, Nuevo Leon, large companies and the Multilateral Investment Fund of the Inter- environmental American Development Bank (IADB) supported an effort by the Instituto Protection Ambiental releases, nearly 70 (IPA), a nongovernmental association of busi- nesses in Monterrey, to train 19 SMEs in the use percent had improved and application of a modified environmental management system based on the ISO 14001 their work environ- model. One of the project objectives was to determine whether EMSs were a useful tool in ment, and over 50 improving SME environmental performance. Four companies could to point to specific envi- percent had ronmental and economic benefits of participating in the project. The project’s report noted that the improved their eco- vast majority of the "root causes" of significant environmental problems identified by the firms nomic performance. could to be addressed through changes in man- agement practices such as improved mainte- nance, improved procedures and better training. Relatively few of the solutions, according to the report, required significant capital expenditures (Lexington Group 2002). These studies and projects point the way to understanding the potential benefits of an EMS, while serving as a reminder that many obstacles and barriers to effective EMS imple- mentation exist. 11 A NORTH AM ERIC AN PERSPE CTIVE
  • 14. 4. THE BENEFITS AND COMMON CHARACTERISTICS OF SUCCESSFUL ENVIRONMENTAL MANAGEMENT SYSTEMS esigning and implementing an EMS can longer generating hazardous waste (IFC 2004). D have tangible benefits for business enter- prises. A system can help a company to In another example, during the development of its EMS a company in Mexico, Químicos y enhance efficiency and minimize resource use Papeles del Norte, identified the use of exces- and waste, thereby reducing costs, help to sive rinse water as a significant environmental Lower Insurance Costs ensure compliance with regulatory require- aspect of its operations: the short production The most reliable financial quantification of the benefits of an environmental manage - ments, encourage employee involvement and runs of incompatible products required the ment system is often lower insurance costs; improve relations with customers. Despite vari- equipment to be rinsed between products. The companies that minimize risks may receive ation in the sophistication, scope and achieve- company implemented a more systematic pro- better insurance rates. The current case stud - ments of environmental management systems, duction programming to eliminate product ies, however, provide only a few examples of small and medium-size enterprises that real- successful EMSs share common characteristics changeovers and increased product storage ized this benefit. In one example, DESC, a that are directly related to the benefits of an capacity. The results were more efficient utiliza- holding corporation in Mexico that owns sev - EMS. The benefits and the characteristics of tion of product and storage space, water savings, eral companies from different sectors, includ- ing the chemical sector, chose to expand its successful EMSs are described in this chapter. reduced product waste and improved labor uti- company-wide EMS to include outsourced lization (Lexington Group 2002). carriers. As part of this effort, suppliers, cus- The Benefits of Environmental Reduced liability is another financial criterion tomers, carriers, terminals and all who were in the supply chain were evaluated. During Management Systems that can be used to measure the success of an the first two years, the main focus was the Various books, articles and studies have identi- EMS. A court or the government may view a carriers, who were audited under a specific fied the benefits an environmental management company with an EMS in place more favorably risk reduction program. By developing tools to evaluate the risks along its transportation system can have for a company. In this section, when determining sanctions. For example, in routes, DESC was able to achieve a substan- these benefits are categorized into five main Nova Scotia a judge dismissed a case against a tial reduction in insurance fees. In turn, the areas that are most relevant to SMEs. pulp and paper mill for a small oil spill because carriers, once they implemented these prac- the company had an EMS in place that addressed tices across their operations, were able to negotiate a reduction in their own insurance. Enhanced Efficiency and Lower Costs spill issues. The judge cited the company’s due Accidental index was reduced from six acci - EMS manuals and case studies point most fre- diligence, stating "the supervisor who found the dents in 2001 to zero in 2004. Part of the quently to the financial benefits of implementing leak . . . knew the equipment, what to do to evaluation tools used came from the Responsible Care System of Mexico’s an environmental management system. Cost sav- stop the leak and did so immediately. . . . He had National Association of the Chemical Industry ings are often linked with consuming fewer been instructed on what to do in the event of (Asociación Nacional de la Industria resources and producing less waste, but savings any oil spill and he did that." R. v. Stora Forest Química—ANIQ) can also accrue from operational efficiencies, a Industries Ltd., [1993] N.S.J. No. 330 (N.S. Prov. Source: Margarita Ferat Toscano, corporate environ- higher level of management efficiency, reduced Ct. Jun 23, 1993) Chapter 7 describes how gov- mental manager, DESC, SA de CV, e-mail message to Ignacio González, CEC, 4 october 2004. liabilities and shorter permitting times because of ernment policies encouraging EMS usage may better relations with regulators and communities. also affect penalty calculations. Operational efficiency usually involves replacing or renovating equipment and facilities, Reductions in Resource Use, Waste and as well as improving the production process Emissions design and paying closer attention to all inputs Many SMEs rate the success of their EMSs by and outputs. Such changes can reduce inputs monitoring the resources used and the waste (energy, water, etc.) or make operations more minimized, both of which are closely related to efficient, so that production is higher, faster or cost savings. Implementing an EMS allows a cheaper than before. Costs are compared pre- company to identify opportunities for improve- and post-EMS implementation. ment and to plan expenses. Key performance Even small changes in operational efficiency indicators include: the volume of raw materials, can produce significant results. During its EMS water and energy consumption, recycling rate, identification process, one company highlighted hazardous and nonhazardous waste generation in the IFC case studies (Figure 3.1) noticed that and the number and volume of releases. Organi- one of its large machines had a serious oil leak. zations use self-generated records, bills or data The leak was quickly repaired with a $5 gasket. from various utilities to measure consumption This easy, inexpensive action cut the amount of and waste pre- and post-EMS implementation. oil consumed by the company by half, resulting Both large corporations and small and in significant cost savings. In addition, the local medium-size enterprises use EMSs to reduce municipal authority reclassified the plant as no resource and energy consumption, as well as 12 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
  • 15. the volume and toxicity of waste generation. the United States, which was cited in the Nation- Fourteen of 15 International Finance Corpora- al Database on Environmental Management Sys- tion case studies claim reduced waste, con- tems study, designed its EMS without employee sumption or toxicity as companies' main goals in involvement, but then engaged employees in a EMS design and implementation, as well as the series of classes and meetings to introduce and primary criteria for evaluating EMS usefulness. reinforce EMS concepts. It also trained a dozen Elsewhere, in a survey of 580 manufacturing employees from the company to act as internal Fourteen of 15 plants with more than 50 employees, Florida auditors. By contrast, another company cited in and Davison (2001) found that facilities with the NDEMS study, a 350-person manufacturing International Finance EMSs resoundingly pointed to recycling and plant, selected a wide range of employees, from reductions in air emissions and solid waste and managers to engineers to line operators, to Corporation case electricity use as evidence of facility-level make up the team responsible for creating the improvement. EMS. The company considered employee studies claim reduced engagement in the design process as important waste, consumption Regulatory Compliance Another frequent indicator of a successful EMS as engagement in implementation. or toxicity as com- is achieving the goal of regulatory compliance. Improved Relations with Customers The criteria an organization selects to measure An EMS can improve relations with customers. panies’ main goals improvement can vary widely and depends on For an SME, improved relations usually means the company’s compliance history and regulato- larger purchasers in a dominant market position, in EMS design and ry burden. Management can use an EMS to such as Ford and GM, which require their sup- monitor the legal requirements and thereby plan pliers to be ISO 14001-certified. Smaller compa- implementation, as expenses associated with permitting, reporting nies, however, may also find that an EMS means and monitoring to ensure compliance with the wider appeal in a more local market. For exam- well as the primary law. Ideally reducing the frequency and severity ple, Framboisière de l'Estrie, a berry farm in of violations and the associated costs. Quebec, was one of the first two farms with ISO criteria for evaluat- An EMS can also help a company to pre- 14001 certification in North America (see side- pare for a more stringent application of environ- bar). It markets its environmental improvements ing EMS usefulness. mental regulations by the government. For and the positive economic benefits it has reaped example, the IFC case studies include the from ISO certification. example of a manufacturer of office furniture that eliminated methyl chloroform from its The Benefits and Common Characteristics cleaning and fastening processes and reduced of Successful Environmental Management the volume of emissions of volatile organic The success of an organization’s EMS can be compounds (VOCs) by converting to a powder- evaluated by monitoring the organization’s based coating system. These pollution preven- progress toward meeting its environment-relat- tion alternatives saved the company more than ed objectives and targets. Understanding the $1.1 million a year and gave the company a common characteristics of a successful EMS will return on its $1 million investment in less than help to ensure that the conditions needed to one year. This effort helped the company to support successful EMS design and implementa- comply more easily with increasingly stringent tion are present. environmental regulations and eliminated incin- eration fees for solid and liquid hazardous Designed with a Strong Business Case in Mind. wastes (IFC 2004). A successful EMS is developed with a strong business case in mind. Its purpose is to improve Employee Involvement the value of the company through risk reduc- Many companies recognize that the success of tion, revenue enhancement and cost reduction. an EMS depends on the participation of the full spectrum of employees. Indeed, employee Supported by Management and Commitment of engagement is at the heart of the Total Quality Resources. Unless the owner and upper man- Management (TQM) process on which EMS agement are committed to and supportive of the principles depend. Different types of employees EMS, it is extremely difficult to obtain the have different insights into environmental per- resources and cooperation needed to success- formance and suggestions for improvements. fully develop and implement an effective sys- Proper implementation of an EMS requires tem. The environmental policy, as endorsed and employee involvement and, if successful, cre- supported by management, defines the strate- ates as a benefit a sense of responsibility and gy of the organization and specifies the scope accomplishment among the employees. and commitments of the EMS to employees, A 90-person metal finishing company in customers and those outside the company, 13 A NORTH AMERIC AN PERSPE CTIVE
  • 16. such as local agencies, investors and communi- of the EMS. A key element of any management ty groups. system is the opportunity it provides for learning from experience. Given the size, resources, and Engaged Employees. When employees at all variety of structures, as well as the obstacles levels of an organization are engaged in an faced by small and medium-size enterprises in EMS, it is more likely to succeed. Under a well- implementing environmental management sys- Improving the Value of the Raspberry designed EMS supported by management, indi- tems, it is important that those systems be flexi- Business vidual employees understand their roles and ble. Whenever possible, the goals and Situated at Johnville, near Lennoxville, responsibilities, receive adequate training and complexity of an EMS should be set by the com- Quebec, the Framboisière de l’Estrie stretches information, and are aware of the potential envi- pany itself. Those goals will necessarily be limit- over 11 hectares. Each year the farm grows and sells 43,000 kilograms of fruit and mar- ronmental impacts of their jobs. Typically, when ed by financial and economic considerations, kets associated products such as syrup. As a employees are engaged in such a program they including the profitability requirements of the result of going through the ISO process, the enjoy a sense of ownership and possess the organization. farm did away with all pesticide use and replaced fertilizers with compost, maintained motivation to make a positive contribution to water consumption while increasing produc- the success of the program. * * * tion surface by 50 percent and reduced the cardboard content of its boxes by 50 percent, Integrated into Business. The most successful With these potential benefits, why aren’t more which reduced its purchase, transportation and storage costs. Overall, its production EMSs are not stand-alone projects or initiatives; SMEs designing and implementing successful costs decreased while yield increased. they are part of the standard decision-making EMSs? One reason is that, in most cases, the process of a business. They also are integrated driving forces are not strong enough to over- into all aspects of a company’s activities, prod- come the barriers. It is essential that those pro- ucts and services. In the NDEMS study, all com- moting an EMS to such enterprises understand panies that had adopted EMSs asserted that they the drivers and barriers faced by an SME. The saw a business value in improving their environ- driving forces or barriers that are most impor- mental performance. tant depend on the type of industry, the size of the business and its customers. Clearly Defined Objectives and Targets. Success- The Case of Salsa de La Laguna ful EMSs tend to set both abstract/overarching In adopting an environmental management and specific/measurable goals. An abstract/ system, employee engagement and buy-in overarching goal may be "transparency," where- can be particularly important when a compa - as a specific/measurable goal may be "Have ny has a recognized brand name. The Guadalajara Environmental Management Pilot Michael document the EMS design and imple- (GEMP) study recounts the case of Salsa de mentation process" or "Reduce air emissions by La Laguna (SLL), a 30-person Mexican com - 35 percent by 2006." Abstract/overarching pany that makes hot sauce and supplies one of the largest tequila manufacturers in Jalisco goals allow for creativity and problem solving, with sangrita. because managers and employees are not The company faced environmental issues bound to follow certain codes. Specific and associated with excessive noise, the dis - charge of raw materials, generation of exces - measurable goals ensure that the abstract is sive waste, effluent discharges to a lake and translated into the feasible and achievable. This an excessive risk of fire. SLL developed a duality also places smaller objectives in the con- comprehensive EMS by mobilizing work text of larger goals. teams to analyze and respond to problems in industrial hygiene, raw material use and con - trol of wastes, effluent discharges and noise. Continual Monitoring and Measurement. Moni- Among the ideas that they, together with toring and measurement are always cited in management and a university consultant, had were sorting solid waste into reusable and EMS success stories, but companies go to wide- recyclable bins, cleaning up work spaces, ly different lengths to monitor and measure improving the maintenance of company vehi- their progress. cles, reducing effluent discharges through water conservation, reducing the use of sani - After setting objectives and targets, a com- tizing chemicals, requiring suppliers to use pany should devise a means of monitoring and strong containers in order to reduce waste measurement, preferably in quantifiable terms. and loss, and rinsing out drums of orange juice to salvage concentrate. Some of these Are changes being implemented? Are the cor- measures resulted in savings of over rect policies being pursued? Is the amount of US$10,000 a year. This new environmental waste being reduced, and, if so, by how much? consciousness went beyond the factory. How much money is being saved through waste According to the report on the project, some workers "began wearing T-Shirts describing reduction? Are targets being met? Are more their new environmental concerns, to speak effective means of reducing waste available? at local schools, and to participate in environ- Should objectives and targets be revised? Ques- mental cleanup activities in the community" (World Bank 1998). tions like these should be asked daily by any company and not limited to the start-up period 14 ENVIRONMENTAL M ANAGE MENT SYSTE MS
  • 17. 5. DRIVERS AND BARRIERS TO EMS ADOPTION BY SMALL AND MEDIUM-SIZE ENTERPRISES riving forces are factors that create or in an environmentally responsible way. The D change an organization’s environmental performance by pushing it to utilize environ- Canadian Federation of Independent Business (CFIB) survey of SMEs revealed that respon- mental management tools, including environ- dents in the most regulated industries—that is, mental management systems. The drivers are those in the primary and agricultural sectors— usually directly related to the benefits articulat- were more likely to adopt a formal environmen- ed in the case studies in Chapter 4: enhanced tal management system. Businesses in these efficiency and lower costs; reduced resource sectors were also subject to higher levels of cus- use, waste and emissions; regulatory compli- tomer requests for EMSs (CFIB 2001). ance; employee involvement and improved relationships with customers. Other drivers Driver - Customer Requirements might be motivators such as building relation- For a small and medium-size business, one tan- ships with government agencies, achieving gible value in creating and implementing an faster approval of projects, seeking fewer EMS is that such a step will meet the require- inspections and less scrutiny, creating a good ments of larger customers, or dominant buyers. public image and responding to pressures from Large multinational companies are increasingly internal stakeholders within a company. requiring their suppliers to adopt environmental Unlike large companies with a recognized management systems—a development that brand name and large public exposure, smaller directly affects SMEs. By choosing not to do businesses, especially suppliers to larger com- business with firms that do not adhere to their The owner of the panies, are unlikely to implement an EMS as a environmental policies, large multinational com- way enhance their reputation with the public. panies are able to greatly influence the environ- business must believe The owner of the business must believe that the mental impacts of their smaller suppliers and EMS will create real tangible value for the busi- distributors. DaimlerChrysler, Ford, General that the EMS will ness. When a strong business case exists, the Motors and Sony, for example, now require ISO business owner’s active support for the design 14001 certification of their primary and second- create real tangible and implementation of the EMS is critical to ary suppliers. Large companies impose these value for the business. help ensure its success. requirements for a variety of reasons. Among them are reduced risk, new European Union Driver - Economic Factors regulations restricting substances in consumer An EMS can, in many instances, create real tan- products, direct financial savings, improved gible value for a business in risk reduction, rev- relations with their customers or regulators and enue enhancement and cost reduction. A small recognition of responsibility for their environ- background survey conducted by the National mental impacts. Environmental Education and Training Founda- An example of the effect large corpora- tion (NEETF) in the preparation of its 2001 tions can have on their supply chain is illustrat- report "Standardizing Excellence: Working with ed by the Environmental Performance Smaller Businesses to Implement Environmental Agreement between the Canadian Automotive Management Systems" found that the top five Parts Manufacturers’ Association (APMA), Envi- factors likely to drive EMS adoption in smaller ronment Canada Ontario Region and Industry enterprises were Canada. The agreement, entered into in 2002, committed participating APMA member compa- 1. business benefits of an EMS nies to be ISO 14001–registered by December 2. tax breaks for EMS implementation 2003 and to take action to reduce emissions of 3. customer EMS purchasing requirements volatile organic compounds, carbon dioxide and for suppliers other substances. APMA members collectively 4. insurance benefits of an EMS account for over 90 percent of the $35 billion 5. a performance-based regulatory system. automotive parts industry production in Canada. This agreement was a response to the supply chain In heavily regulated sectors, an EMS may requirements of DaimlerChrysler, Ford Motor be a way to demonstrate to regulators, lenders, Company and General Motors. Specific targets insurers and buyers that a company is managed and timelines for this initiative are an aggregate 15 A NORTH AMERIC AN PERSPE CTIV E
  • 18. Mexico’s National Association of the Chemical Industry (Asociación Nacional de la Industria Química—ANIQ) was the first association to design its Responsible Care program as an environmental health and safety management system (Sistema de Administración de Responsabilidad Integral—SARI). reduction of 20 percent in VOCs and 3 percent for becoming a member of ANIQ. Members must in carbon dioxide and CEPA toxic substance commit themselves is to actively participating in substances (where applicable) by 2007.7 assistance activities designed to support the A recent pilot project by the World Envi- Responsible Care program in member SMEs. ronment Center (WEC) illustrates this trend. The Responsible Care had a strong impact on WEC is a not-for-profit organization composed the decision by the National Association of of many large multinational corporations. The Chemical Distributors (NACD) to develop an Center’s Supply Chain Management Partnership environmental code of its own (the NACD has promotes the adoption of improved environ- members in Canada and the United States, and mental management techiniques and cleaner many of its members are small businesses). The production programs among companies that NACD code is based on Responsible Care, but supply WEC member companies. The WEC is is stronger in several respects; it requires third- implementing pilot projects with multinationals party verification of members’ performance, as and a select number of their suppliers in Mexico, well as health, safety, and security, and has a Brazil and China (where the project is in the history of suspending and terminating members planning stage). In Mexico, the project involves for noncompliance (Nash 2000). Janssen-Cilag, an operating subsidiary of John- The Environmental Commitment and son & Johnson that produces drugs for clients Responsibility program of the Canadian Electric- around the world, and Alcoa Fujikur, whose ity Association (CEA), which counts small and lines of business include automotive and elec- medium-size businesses among its members, tronic distribution systems and fiber-optic cable. stipulates that adoption of an ISO 14001–con- sistent EMS is a condition of membership. Driver - Trade Association Requirements Under the Environmental Commitment and Some trade associations require their members Responsibility program, a verification team visits to have an environmental management system a selected number of utilities each year to deter- The Importance of the Business Owner in place or to adhere to environmental codes of mine whether the EMS implemented satisfies For small and medium-size enterprises, a cen- conduct. For example, national chemical associ- the program’s requirements. tral factor in the implementation of an envi- ronmental management system is the ations in 52 countries run Responsible Care® For SMEs, market forces are particularly leadership of the top manager in pushing for programs. Under Responsible Care, member important. This is especially true in Mexico, continual improvement. Observers have companies must commit to adopting a set of which has a large, informal economy and whose noted that a commitment to achieving envi- ronmental improvements is a far bigger factor guiding principles, codes, guidelines and check- smaller businesses may be subject to fewer reg- in achieving environment results than merely lists on health, safety and environmental matters, ulatory pressures. A recent Inter-American having an EMS in place; an EMS just makes a and to developing indicators and verification Development Bank study of ISO 9000, and to a company be able to achieve these improve- ments. In fact, a Canadian Federation of Inde- procedures. They must communicate their "good lesser degree ISO 14001, in certain areas of pendent Business (CFIB) survey found that faith efforts" to implement the codes to employ- Latin America, including Nuevo León in Mexico, for 87 percent of respondents the personal ees and stakeholders.8 found that a key determinant of the quality of views of owners were the primary motivation Mexico’s National Association of the the environmental management system was the for improved environmental performance (CFIB 2001). Chemical Industry (Asociacion Nacional de la extent to which management demanded the The Guadalajara Environmental Manage- Industria Quimica—ANIQ) was the first associa- system (IADB 2004). However, despite these ment Pilot (GEMP) and Proyecto Adminis- tion to design its Responsible Care program as market forces, for most SMEs the barriers to tración Ambiental Monterrey (PAAM) studies highlight the importance of manager support an environmental health and safety management EMS adoption outweigh the drivers. for employee involvement in the EMS process. system (Sistema de Administracion de Respons- Those managers who enthusiastically adopted abilidad Integral—SARI). It incorporates elements Barriers to EMS Adoption EMS concepts and who worked with their employees achieved successful EMS imple- of ISO 14001 and fulfills other requirements of Barriers are factors that hamper and can even mentation during the study time period, different known management systems related to bring to an end the design, implementation and whereas those managers who did not with environmental, health and safety issues. Adoption operation of an environmental management sys- their employees failed. A manager who sees an economic benefit in EMS implementation of the Responsible Care program is a condition tem. Even when driving forces exist, SMEs may and actively supports its design and develop- face imposing barriers when designing and 7. B. Brad Cummings, manager, Pollution Prevention and ment is a critical factor in EMS implementation Innovative Technologies, Environment Canada Ontario Region, implementing an EMS that larger companies are (Lexington Group 2002). e-mail message to Tim Whitehouse, CEC, January 28, 2005. less likely to face. A Lack of knowledge about 8. See <http://www.responsiblecare.org>. and awareness of environmental management 16 ENVIRONMENTAL MANAGE MENT SYSTEMS