OPPORTUNITIES TO STRENGTHEN THE REGISTRATION AND ACCREDITATION SYSTEM FOR ISO 14001 CERTIFICATION

Table of Contents	Page
List of Tables	ii
List of Figures	ii
Executive Summary	1
1 Introduction	11
1.1 Background	11
1.2 Delimitation of Scope	17
1.3 Limitations	18
2 Research question addressed	19
2.3 The problem	19
3 Research Methodology	22
4 Analysis and results	27
4.1 Findings	27
4.2 Observations and Analysis	30
1. Role and nature of stakeholder advisory committees	30
2 Specifying scope of registration	32
3a Continual improvement	36
3b. Prevention of pollution	39
4 Legal compliance	41
5 Determining audit days for assessment, re-certification and surveillance	43
6 Environmental competency and ongoing job training	46
7 Aspect and impact assessment	48
8 Comprehensive internal audits	55
9 Record of communications with external interested parties	56
10 Re-certification options--effectiveness and reassessment	57
11 Sampling plan for a single certificate covering multiple locations	60
12 Audit methodology regarding intent, element priority and stages	62
5 Summary	68
Acknowledgement	69
References	70
About the author	73
Further Information	73

Executive Summary

This paper examines the following: 1) differences in accreditation requirements between the accreditation bodies of American National Standards Institute - Registrar Accreditation Board (ANSI-RAB) and the Dutch Council for Accreditation (Raad voor Accreditatie, i.e. RvA) regarding International Organizations for Standardization (ISO) 14001 certification process, 2) how these differences in accreditation requirements influence registrar practices, and 3) what inherent influences these differences ultimately appear to have on environmental performance of their client organizations.

A detailed clause by clause comparison of ANSI-RAB NAP (American National Standards Institute, Registrar Accreditation Board National Accreditation Program) E3.1 and E3.2, Europe’s EA-7/02 and International Accreditation Forum (IAF) Guidance to ISO 66 found significant difference in 12 areas of present and proposed accreditation requirements.

Nine registrars, responsible for over 40% of North and South American as well as world-wide ISO 14001 certification, participated in open ended surveys to explore if and how these differences in accreditation requirements corresponded to different registrar practices. (See Figures 4.1 and 4.2)

Organizations located in America and from the electronics industry were emphasized in the universe of registered facilities to be surveyed. From this universe, a random sample of three to four organizations from each of the nine participating registrars were selected for the open-ended survey format. (see figure 1.1) Thirty-one of thirty-four agreed to participate, giving a response rate of 94%. These organizations were surveyed regarding the following areas of concern:

1) the significant impacts chosen,

2) the methodology used to identify these significant impacts,

3) the objectives chosen,

4) the aggressiveness of targets set,

5) whether the data was normalized or not,

6) target attainment,

7) the organizations’ interpretation of prevention of pollution,

8) the organizations’ interpretation of continuous improvement,

9) compliance to legal regulations.

10) the value received from both the certification and the registrar itself

Responses for areas 1 through 9 were then rated against a generalized set of benchmark performance indicators reflecting industries’ best practices in reducing their most challenging environmental impacts. (see Figure 4.3)

70% of all US certified organizations are done so by European accredited or headquartered registrars. In order to better discern accreditation influences and national headquarters influences, the registrars and their organizations were classified into 3 different categories: Group 1 represents American based registrars with American (ANSI-RAB) accreditation and their client organizations, Group 2 represents American based registrars with European (RvA) accreditation and their client organizations, Group 3 represents European based registrars (with European (RvA) accreditation) but with American (ANSI-RAB) accreditation (in America) and their client organizations.

The study discovered and analyzed twelve major differences in accreditation requirements. It concludes that several of these differences are associated with significant registrar practices. For some of these differences in registrar practices, there appear to be associated differences in environmental performance indicators at the registered entities.

Note that this analysis is best viewed as a preliminary analysis and the observations should not be viewed as having statistical significance.

Nevertheless, the conclusions and observations should be valuable to those trying to understand and improve the inner workings of the accreditation and registration systems.

The following is a summary of these differences and their ramifications on registrar practice and organizational environmental performance characteristics.

1. ROLE AND NATURE OF STAKEHOLDER ADVISORY COMMITTEES:

A balanced stake holder advisory committee may enhance system impartiality, creditability and ultimately the environmental performance of conforming entities. European and American accreditation bodies differ in the extent to which they require registrars to use balanced stakeholder advisory committees as a vehicle to ensure impartiality. RvA’s emphasis in particular on the use of such committees appears to have a significant positive impact on the actions of its accredited registrars. Some stakeholders may view a few of the differences as detailed later in this section as pushing the bounds of what is actually required by ISO 14001 and hence not realizable universally. Nevertheless, as a vehicle to achieve impartiality, it seems likely that the net result of increased use of empowered, balanced stakeholder advisory committees would also enhance the credibility and environmental performance of conforming entities.

2 SPECIFYING SCOPE OF REGISTRATION

The overall intent of an organization’s scope of registration is to capture within the Environmental management system the environmental aspects of an organization’s activities, products and services that it “can control and over which it can be expected to have an influence."[1] (Fukuda 1999b). American accreditation requirements do not offer clear guidelines as to how to define scope of registration. This has lead to a wide variation between registrars’ definition as to what needs to be include under the scope of registration regarding production and research facilities, internal and corporate departments and level of supplier influence. Flexibility for individual entities to define the scope of registration may be appropriate and offer certain advantages, but it has the down side of reducing the credibility of the system as a whole.

3 CONTINUAL IMPROVEMENT and PREVENTION OF POLLUTION

Continual improvement and prevention of pollution are areas where there exists a deep chasm between various ISO 14001 Technical Committee (TC) 207 national authors, particularly Europe and America. This difference spilled over when establishing specifications in ISO 14001.

European TC 207 delegations generally wanted to measure environmental improvement in terms of reduced environmental impacts created, such as reduced toxic pollutants, energy used, etc. Similarly, European countries generally have regarded prevention of pollution as defined by EVABAT (Economically Viable Application of Best Available Technology), resulting in non-standard but constantly evolving implementation of newer pollution control technologies.

The American TC 207 delegation argued that continual improvement should be measured with respect to enhancements in the performance of the system itself, such as how well internal audits capture non-conformities, improvements in management’s response to spills. Regarding prevention of pollution, although some forces in the US strongly argued for use of the pollution prevention hierarchy of reduce/recycle/reuse before implementing technological control solutions, this view did not carry the day within ISO 14001.

These differences in perspectives essentially prevented both European (EA-7/02) and ANSI-RAB (E3.1) accreditation bodies from aggressively addressing requirements to address the assessment of continual improvement or prevention of pollution. However, recent IAF Guidance to ISO 66 requirements have included language which supports registrars in taking a stand on systems that do not show evidence of the commitment to continual improvement or prevention of pollution. But it does not get into the issue of how progress should be measured.

Group 2 and 3 registrars appear to be close to implementing this recently established requirement, particularly regarding continual improvement.

Interestingly, the organizations certified by group 3 registrars, although not required to, were found to generally measure their own continual improvement in terms of reductions in adverse impacts as opposed to relying on system improvements to show continual improvement. Furthermore, these same entities generally choose to show commitment to prevention of pollution by focusing on the reduce/recycle/reuse protocol (i.e.-pollution prevention) rather than relying on end-of-pipe treatment, even though not required to do so the standard or by either American or European accreditation requirements. Critiques have asserted that such an approach should yield larger gains in environmental benefits than would a focus only on system improvement and end-of-pipe reduction.

American accreditation bodies should consider guidance that would call for a formal assessment of the mechanisms by which an organization intends to realize and measure their commitment to continual improvement and prevention of pollution. This suggestion is made even given the current absence of emphasis on substantive verses process improvements and a lack of emphasis on pollution prevention as compared the more broadly defined prevention of pollution.

4 LEGAL COMPLIANCE

Placing the results of an internal compliance under the protection of “Attorney-Client privilege” is a misapplied strategy sometimes used by American companies to avoid self-incriminating evidence being used against them in the event that a civil lawsuit was filed for violation of regulatory requirements. Unfortunately, this strategy also prevents registrars from viewing these audits in order to confirm the ISO 14001’s requirements regarding commitment to legal compliance are being realized.

Proposed American accreditation requirements have directly addressed this issue. They prohibit this practice, European requirements do not. As 70% of ISO 14001 registered organizations in the US are certified by a European based or accredited registrar, it would be desirable if European requirements addressed this issue more directly.

5 DETERMINING AUDIT DAYS FOR ASSESSMENT, RE-CERTIFICATION AND SURVEILLANCE

RvA has taken the lead in eliminating much of the variability caused by lack of a specific accreditation requirement by establishing a mandated minimum number of audit days for specific industry sectors and employee size. Registrars accredited by RvA (group 2 registrars) generally have procedures that quote a higher number of assessment days than Group 1 or 3 registrars.

Without a consistent and minimum number of audit days and corresponding audit-day rate for specific industry sectors and employee count, registrars are forced into a competitive downward spiral, submitting bids with fewer and fewer audit days assured, spiraling down without any minimum floor.

This is a controversial area for registrars. Some who would like to think themselves above this, publicly denounce minimum audit day and rate requirements but privately agree that something needs to be done. Accreditation bodies stepping up to establish a level playing field would do much for strengthening ISO 14001 certification credibility and building stakeholder trust.

6 ENVIRONMENTAL COMPETENCY AND ONGOING JOB TRAINING

The competency of registrars and their auditors is a key component in accurately and fairly assessing an organization’s EMS. It is an important aspect in gaining stakeholder confidence in the integrity of the system and in assuring environmental improvement.

European accreditation requirements have a more detailed and specific set of requirements for auditor competency than do American accreditation requirements. European guidelines include specific requirements that the auditor team is environmentally competent in the specific industry sector regarding aspect and impact assessment, control and reduction techniques, and that the registrar itself has environmentally industry-sector competent system and people reviewing the contract and granting and withdrawing the certificate. However, no evidence could be found to verify that registrar practice follow these more specific requirements.

RvA uses a more rigorous means to verify auditor competency than ANSI-RAB, through its program that reviews the auditor education and experience and verifies the auditor’s competency through witnessed assessment. Evidence of registrar practice verified this requirement. However the requirement is slated to be discontinued due to its high cost and competitive pressures.

Thus, world-wide enhancement of the requirements for registrar and auditor competency would likely help to insure ISO 14001 certified organizations have a level, high quality playing field.

7 ASPECT AND IMPACT ASSESSMENT

The process of identifying and assessing environmental aspects and their impacts is an important corner stone of an effective EMS. Equally important is the criteria used to prioritize the significance of the identified aspects. Failure to either identify actual aspects or effectively assess and rank their significance can lead to an ineffective system. European accreditation requirements attempt to elucidate this area that is often not well understood. Overall, registrars with either European accreditation or headquarters had practices that indicated a higher sensitivity to aspect and impact assessment. Yet, evidence could not be found in all cases that these more detailed European guidelines were being applied by the European accredited registrars.

Organizations interviewed were rated on their accuracy of identifying aspects, impacts and significance relative to benchmark industry standards, and their aggressiveness in establishing objectives, targets and measurements to reduce them. Higher scores were achieved for organizations that are registered under either European accreditation requirements or have European headquarters. This raises the likelihood that European accreditation efforts to clarify this arena is being passed down from the registrars to the conforming organizations. American registrars could assist this process by adoption and enforcement of these European and IAF guidance. Likewise European accreditation bodies could provide increased confidence that organizations are consistent with these measures through establishment of a more vigorous means of verifying registrar practices in these areas.

8 COMPREHENSIVE INTERNAL AUDITS

The amount of knowledge gained from internal audits is in part a function of the training, thoroughness and knowledge of the internal auditors. European accreditation specifications, which list specific criteria for use in judging the comprehensiveness of internal audits, appear to increase the thoroughness with which registrars assess the effectiveness and comprehensiveness of an organization’s internal audits. Adoption of these requirements by the American accreditation body would probably likewise assist in encouraging more thorough and effective assessment of internal audits by registrars. This is likely to eventually lead to improvement in the client organization’s internal criteria for qualifying auditors and executing internal audits, and ultimately to improved the performance of the subject EMS generally.

9 RECORD OF COMMUNICATIONS WITH EXTERNAL INTERESTED PARTIES

In order to show evidence of conformity with ISO 14001 clause 4.2.d--specification on the commitment to compliance, as well as to ensure the ISO clause 4.3.3--requirement that the viewpoints of interested parties are considered when establishing objectives and targets, it is prudent for registrars to review communications from regulatory agencies and other interested parties, such as environmental advocacy groups. This has been addressed by ISO 66 and European accreditation bodies with a specific clause requiring registrar access to all records of communication. American accreditation guidelines do not require the same openness of records. Although there is a special clause added by the American accreditation body to ensure that compliance records are reviewable by the registrar, (Legal Compliance section 4), there is no similar statement requiring that all communication records pertinent to the EMS be reviewable by the registrar. This lack of mandate for complete disclosure of EMS appropriate records reduce the extent to which input from interested parties are utilized within the EMS audit and may lessen the audits' effectiveness and credibility.

10 RE-CERTIFICATION OPTIONS--EFFECTIVENESS AND REASSESSMENT

To ensure that an organization’s EMS is periodically reviewed in totality, ISO 66, clause 5.6.1 stipulates that the registrar must carry out regular surveillance and re-assessment at sufficiently close intervals to verify that the organization’s EMS continues to comply with ISO 14001 and the registrar’s other requirements. Accreditation bodies have detailed the guidance on this requirement. European accreditation requirements differ in intent and detail from that of American accreditation requirements. European accreditation requirements emphasize that the effectiveness of the system should be verified and that the system should normally be fully reassessed after a period of 3 years. American accreditation requirements do not ask for registrars to assess the effectiveness of the organization’s system, and offer, as an option, bi-annual surveillances to replace a full reassessment of the system.

Despite the incentive to organizations to create verifiably effective EMSs by these European accreditation requirements, evidence could not be found that this European accreditation requirement was being thoroughly enforced within the surveyed registrars. Neither Group 1 nor Group 2 and only half of Group 3 registrars were found to have assessment practices which formally evaluated organizations for EMS effectiveness. Additionally, despite European accreditation requirements requiring full reassessment, all registrars generally follow American accreditation requirements that specifically allow for biannual audits. This however, was a benefit to organizations, as a significant number of organizations were found to highly value surveillance audits for their input into the EMS system.

Overall, guidelines that call for an assessment of the organization’s effectiveness (e.g., the European specifications), and for more frequent assessment (e.g., the American specifications) seems to represent superior approaches. In addition, the issue of registrar’s adherence to requirements appears to warrant more attention.

11 SAMPLING PLAN FOR A SINGLE CERTIFICATE COVERING MULTIPLE LOCATIONS

For marketing and economic purposes, some corporate organizations select to certify several sites under one certificate. ISO 66 does not specifically address this situation[2] and thus it is up to individual accreditation bodies to form the rules that govern such a situation.

Accreditation bodies have developed different requirements. European accreditation bodies have listed several considerations a registrar needs to take into account when designing a sampling plan. Additionally the European accreditation requirements require that all sites be visited within a 3 year period, regardless of the number of sites. American accreditation guidelines stipulate specific requirements regarding the definition and sampling plan for multi-site certificates. However the sampling plan does not require all sites to be audited within a 3 year period if the corporation has more than 52 sites.

Regardless of accreditation requirements however, all registrars were found to follow the American accreditation requirements. This situation raises questions as to the adequacy of assessment for multi-sited certificates as well as the adequacy of European accreditation oversight of this requirement.

12 AUDIT METHODOLOGY REGARDING INTENT, ELEMENT PRIORITY AND STAGES

There are a variety of methods to assess an organization. Having an overall understanding of the intent of the audit helps all registrars ensure that the assessment achieves its purpose. Similarly, a common understanding of the more important elements of the standard helps registrars to prioritize non-conformances and keep findings in perspective. Finally, assessing the organization in two separate on-site assessments (commonly referred to as preliminary and certification assessments) has proven to be an effective means for registrars to assign the appropriate auditor(s) for the certification assessment of the facility, avoids the expenditure of client organization funds on assessment when they are not yet ready to undergo a full audit and averts inappropriate pressure to certify borderline facilities.

Other than requiring a two stage audit, ISO 66 does not elaborate on the methodology of the audit. Accreditation bodies in Europe and America have chosen to clarify these requirements. There are significant differences however, between their approaches, particularly: 1) the intent of the second on-site registration audit, 2) which elements of ISO 14001 considered to be of highest priority, and 3) the location the first stage of the audit should be held.

This section of the survey concentrated on registrar practices regarding on-site assessment during the first stage of the audit.

Presently, American accreditation requirements do not require an on-site assessment during the first stage of the audit. It was found that the majority of Group 2 and 3 registrars require on-site stage 1 assessment, but the practice varied widely within group 1 registrars. This leads to a higher risk that: inappropriate auditors are assigned to the on-site audit, European accredited registrars would undergo a competitive disadvantage, organization’s waste financial resources due to the higher risk of failure and auditors are under increased pressure to certify borderline facilities.

PARTICIPANT OBSERVATIONS

The main aim of this research was to identify and discuss areas where differences in accreditation requirements might affect the level of reliance that can be placed upon registration of ISO 14001.

The numerous issues discussed in this paper clearly indicate that accreditation requirements do affect the level of reliance and the confidence that can be placed upon the assumption that registration to ISO 14001 will lead to improved environmental performance. Several ideas have been raised in discussion with accreditation bodies and registrars as to how to reduce these differences and increase the credibility and reliability of ISO 14001 certification. These ideas are presented here, not as recommendations, but rather to stimulate discussion.

Create a more balanced stakeholder advisory panel within ANSI-RAB’s NAPC

Increase the role in ANSI-RAB advisory panel played by environmental departments within government, along with other stakeholder representatives of the general public. Representatives that have formed and maintained RAB’s accreditation requirements are not viewed as balanced between the various stakeholders affected by ISO 14001. This is seen as a main reason why EA-7/02 requirements have not been adopted

Harmonize accreditation requirements world wide

Strengthen the accreditation bodies concerted effort to harmonize accreditation requirements through IAF guidance. The efforts up to now, as have been shown, have not assured consistency. It has been suggested that accreditation bodies could open up the peer review process to more stakeholders than just other accreditation bodies. (Note: an accreditation peer review is an audit of one accreditation body by other accreditation bodies) This would serve to both gain the confidence of a broader base of stakeholders and influence the depth and direction in which the peer review is done, emphasizing a more thorough review of the assessed registrar’s practices in assessment days, auditor qualification, and continuous improvement assessment practices.

De-link the system’s financial dependence

Reducing the financial link between the users and providers of accreditation and registration service is paramount to being able to maintain high accreditation requirements. The financial dependence between registrars, their clients and to some extent, their accreditation body is viewed as a force in weakening the environmental criteria within assessment protocol. Industry supports and finances certification and therefore appears to have access to and financial control over the system. Accreditation bodies earn their money through fees on the registration of an organization. Three ideas have been suggested in this area:

· Establish an agreed upon charge per audit day and a minimum number of audit days per industry sector, employee count and other crucial variables. This will help reduce the competitive force which drives registrars to constantly reduce both the number of audit days per facility and the competence of their auditors

· Form a pool of money for registrars who drop clients who have not effectively implemented ISO 14001 EMS. Payment would be equivalent to the general profit lost from dropping the client over a period of two years. This would reduce the incentive to keep clients for financial reasons who are not living up to the spirit within ISO 14001.

· Create government and NGO funding to partially support accreditation bodies. This would serve to reduce financial dependence upon industry and potentially begin to represent environmental stakeholder interests.

	Performance category	Score Ratings for each category based on the following criteria:
2	ASPECT AND IMPACT REVIEW METHODOLOGY	5 = Use of regulatory criteria 6 = #5 and natural resource reduction criteria, global warming criteria 7 = # 6 plus use of environmental expert, interest parties criteria, bio-diversity criteria 8 = #7 plus use of non-regulated toxicological criteria 9 = # 8 plus Life cycle analysis of cradle to (cradle) 10 = #9 plus product use criteria, integrated into business strategy e.g. Interface, Electrolux
3	OBJECTIVES	5 = Deal with reduction of regulated material, recycling of office refuse 6 = #5 plus deal with identified significant impacts concerning energy or water or natural resources 7 = #6 plus deals with identified significant impacts concerning recycling of industrial waste 8 = #7 plus “zero waste” objectives 9 = #8 plus LCA objectives (if appropriate) 10 = #9 plus Design for Environment objectives (if appropriate)
4	TARGETS	Certified 1.5 years or less 5 = no goals established 6 = 5-10% 7 = 11-15% 8 = 16-25% 9 = 26-49% 10 = >50%	Certified 1.5 years or more 5 = 0-5% 6 = 6-10% 7 = 11-15% 8 = 16-20% 9 = 21-25% 10 = >25%
5	INDICATORS	5 = Feasibility study 6 = non normalized indicators of achievement 7.5 = mix of normalized and non normalized indicators of achievement 9 = normalized indicators of achievement
6	TARGET ATTAINMENT	1 = objective dropped 2 = no target(s) 3 = met target(s)+/- 10% 4 = exceed target(s) by 15-49% 5 = exceed target(s)>50%
7	TOTAL OBJECTIVE AND TARGET PERFORMANCE	Total based on categories 3-6
8	CONTINUOUS IMPROVEMENT	1 = system improvements only 2 = procedure requires system improvements 3 = environmental performance attained through objective and targets 4 = procedures detail environmental and system improvement
9	POLLUTION PREVENTION	1 = end-of-pipe regulated pollution reductions 2 = procedure details end-of-pipe pollution requirements 3 = reduce material consumption through recycle, reduce programs 4 = procedure specify #4
10	LEGAL COMPLIANCE AND INCIDENCES	1 = Some NOVs (Notice of Violation from State or Fed.) incidences 2 = No NOVs 3 = No NOVs, Compliance target specified and measured
11	Overall Total Value
12	Registrar value?
13	Certificate value?

OBSERVATIONS AND OPPORTUNITIES

European and American accreditation requirements have evolved significantly different interpretations in meeting the requirements for accreditation bodies as stipulated by ISO 66.

There are a number of possible causes for these differences, including composition of accreditation body advisory committees, experience with environmental management systems and historical relationships between industry, government and society. The following section analyses and discusses these differences in interpretations and note any resulting differences regarding registrar practice and environmental performance characteristics that arose in the analysis of collected data. The discussion is grouped into the twelve major topics noted earlier. Some have multiple sub topics.

1. ROLE AND NATURE OF STAKEHOLDER ADVISORY COMMITTEES

Accreditation requirements

ISO 66 requires a balanced committee of significantly concerned parties to advise the registrar regarding the content and functioning of the certification system[6]. It asks that they have formal rules and structure for the appointment and operation of these committees, that the members be free from commercial, financial and other pressures that might influence decisions, and that members are chosen to provide a balance of interests on a committee on which no single interest predominates[7]

European accreditation requirements further detail these requirements.

Regarding content and functioning of the certification system, European requirements ask that the committee be involved with ensuring registrar impartiality and independence at the levels of policy, registration decisions, and auditing[8]. Concerning the committee’s structure and membership composition, the requirements recommend that major interested parties be given the opportunity to participate, including government, consumers and NGO’s, with no single interest being allowed to predominate[9]. The specification further requires that decisions made by these groups of advisors be respected[10].

American accreditation requirements differ in degree of emphasis and examples for impartiality. In particular, the example of what constitutes an impartiality committee does not include reference to likely interested parties, such as industry, government, consumers or NGO’s[11]. In addition, American accreditation requirements do not clarify the areas that the impartiality committee should address, nor that the registrar needs to respect the advice of this committee.

Registrar practices

Group 2 registrars were found to compose advisory groups that represented a higher number of diverse viewpoints than other registrar groups, averaging 20% composition from areas other than industry, including at least 1 participant from environmental advocacy groups (see Figure 4.1-Impartiality: Balance)

Group 1 and group 3 registrars averaged committee membership of 10 % or less from government, academia and environmental advocacy.

Additionally, group 2 registrars were also generally found to develop registration strategies that are more sensitive to assessment of interested parties’ viewpoints and in developing assessment criteria used to audit specific industries.

Figure 4.2

Comparison of accredited registrar practices 8-14

Figure 4.1

Comparison of accredited registrar practices 1-7

Advisory committees with a balance of industry and environmental advocates tend to increase registrar focus on assessment criteria for ensuring the adequacy of consideration of interested party’s views. One Group 2 registrar for example uses a committee of 16 advisors to determine registration policy. It gives veto rights to the three representatives from academia, environmental advocacy and government. Despite the unequal representation from outside industry, this created a fairly balanced situation useful in developing assessment procedures which insure interested party’s viewpoints are taken into account. For example, ISO 14001 requires that the views of interested parties be taken into account when establishing environmental aspects, objectives and targets (ISO 14001 Clause 4.4.3 and 4.3.3). This Group 2 registrar’s advisory council advised that the registrar ensures stakeholder views are reviewed by requesting, at a minimum, that the client organization send out registered letters to neighborhood stakeholders and compile return correspondence prior to assessment.

Another advantage of using a broad base of interested parties was the up-to-date knowledge of environmental concerns that were brought to the table by one stakeholder regarding items such as loss of biodiversity, resource depletion, persistent bio-accumulative toxins, pesticides and genetically modified organisms. Concerns such as these are not typically emphasized by industry with its regulatory focus.

In yet another example, one Group 2 registrar used its advisory committee to gain valuable insight into assessment of industries with which it did not have prior experience or needed special expertise. RvA suggests this approach in order to develop an assessment protocol and as an a means to expanding their scope of accreditation. Scope of accreditation is a practice used by several accreditation bodies ( for example UKAS and soon-RvA) to certify industry sector expertise of registrars who have shown competence in assessing organizations within a specific sector.

Environmental performance characteristics

Expanded use of interested parties on stakeholder impartiality committees were reflected in higher scores by their clients. In particular, the environmental performance characteristic of Aspect and Impact Review methodology (see Fig 4.3, ASPECT AND IMPACT REVIEW METHODOLOGY). Organizations certified by Group 3 and Group 2 registrars respectively scored 15 and 20% higher in this category than organizations certified by Group 1 registrars. The difference reflects an organization’s more stringent aspect and impact assessment methodology that include the additional criteria of interested parties and bio-diversity concerns, and the use of environmental expertise.

Discussion

It appears that if American accreditation specifications were to increase registrars’ emphasis on incorporating a broad group of stakeholder interests to ensure impartiality, the results would require registrars to include a more balanced group of stakeholders in their advisory board. This in turn has shown to increase the registrars' sensitivity of interested party’s viewpoints as well as non-regulated aspects and impacts during the assessment of the organization's aspect and impact procedures. The results of which motivate organizations to have a more aggressive method in aspect and impact identification..

Additionally, inclusion of a broad base of interested parties increases support for ISO 14001. Systems that incorporate viewpoints of all representative groups inherently share a higher degree of confidence because the resulting requirements represent the desires of all groups involved. The more confidence parties have that the system responds to all stakeholders, the more confidence they have that the process is fair and effective.

Utilization of a diverse group of stakeholders involved in co-creating registrar practices, where no one group dominates, creates a democratic representation of the various environmental concerns. This system, with its balanced self generating method of checks and balances, would achieve the overall objective of creating an impartial system.

Adoption by American accreditation bodies of impartiality requirement similar to European, ISO 66 and IAF requirements would have a positive effect on registrar practices and environmental performance characteristics.

2 SPECIFYING SCOPE OF REGISTRATION

Accreditation requirements

The overall intent of the organization’s scope of registration is to capture within the Environmental management system the environmental aspects of an organization’s activities, products and services that it “can control and over which it can be expected to have an influence.” (ISO 14001 1996, Fukuda 1999b).

European accreditation requirements detail this by including a reminder that significance need not be site specific and can includes areas which the organization can be expected to have an influence[12] . These suggested areas are “suppliers, customers or related organizations which create additional environmental aspects for the organization".[13]

Additionally, European accreditation guidelines specifically require the registrar to insure that both the procedure for identifying aspects and their impacts and the criteria for determining significance is sound. [14] (See section 7 part E).

European accreditation requirements specify that the registrar has the competency to insure that “typical environmental aspects and associated impacts, arising from the complete range of the organization’s activities, correspond to those identified in the contract[15]

ISO 66 requirements and IAF Guidance to ISO 66 stipulate that the scope must refer to specific activities at defined sites under clearly defined management[16]. European requirements further clarify this requirement by defining considerations to: management, site boundaries, interfaces and regulatory licenses in order to help insure that its scope is appropriate[17].

Combined, these European and IAF requirements detail an extensive set of requirements to guide their accredited registrar as to defining the scope of registration. Yet, it is considered by some to still be lacking in specific direction for determining scope of registration.

American accreditation, on the other hand, asks only that the scope is appropriate and accurate and refers to ISO 14010 and 14011[18]. Analysis of ISO 14010 and 14011 do not define an appropriate scope other than in general terms such as “the audit scope describes the extent and boundaries of the audit in terms of factors such as physical location and organization activities as well as the manner of reporting.[19] This uncertainty is compounded by the fact that ISO 14010 and 14011 permits entities, in consultation with their registrar, the authority to define the scope of registration the organization wants covered in their certificate[20].[21]

American accreditation requirements do not specify that the aspect and impact analysis need be sound, nor require the competency of the registrar to insure that “typical environmental aspects and associated impacts of the organization’s activities, correspond to those identified in the contract identified.

Registrar practices

Group 1 registrars were generally found to use less specific guidelines in scope determination then the Group 2 and Group 3 registrars (see fig 4.1, Specifying Scope of Registration). This conclusion was based on the following findings:

1. All of Group 1 and one each from Group 2 and Group 3 registrars stated that they allow product specific activities to determine the scope of registration. This allows for organizations to pull departments and product lines from the scope of registration.

2. One Group 3 registrar stated that they determine scope of registration based on the assets the organization has. Thus they look at the specific equipment the company has to define its scope of registration.

3. One Group 3 registrar stated that it depends upon what the organization’s EMS has direct control over. It does not use the definition of what the organization is expected to have control over to define the organization’s scope of registration. Additionally this definition is not dependent upon policy or significant aspects.

4. The majority of Group 2 registrars and one group 3 registrar stated that they require all aspects and impact relative to the site. It does not allow for product line nor department exclusions. However, this criteria is dependent upon the aspects identified, which in itself may be open to contention. It does nonetheless make reference to policy or what areas the organization has or is expected to have control or influence over.

Group 3 registrars are thought to have similar requirements to Group 2 due to the influences from their European headquarters. All of Group 3 registrars have European accreditation at their base location in Europe.

Another way to view the situation is to look at the registrars listing of their individual client's scope of registration. Some registrars delineate their client organization’s specific activities; others only give site location and “all associated activities” as its EMS scope. One registrar in particular summed up the situation as follows: “[registrar listing of the organization’s scope of registration is] all over the place – nobody is doing a good job.”

Environmental performance characteristics

Identifying significant aspects and their impacts relates directly to the organization's scope of registration. For example, when an organization has a design department, they would be expected to identify aspects of their design which have significant impacts. Thus a company manufacturing cooling devices would be expected to identify the specific refrigerant media as a significant aspect and ozone depletion as its impact. Similarly, a company manufacturing carpet would be expected to identify its material as its significant aspects and landfill and resource depletion as its impact.

The open-ended environmental performance survey asked registered organizations which aspects of the organization’s environmental review were deemed significant. Responses were categorized and then rated as to its level of aggressiveness in attacking industry-specific significant environmental aspects. Organizations that had influence over their design AND expected aspects and impacts were identified scored high. Organizations that had influence over their design AND expected impacts and aspects were not identified scored lower. Although there is a large variation in scores for all groups, organization’s certified by European-influenced registrars (Group 2 and Group 3) averaged a 9% and 13% higher score respectively than Group 1 registered organizations in identifying significant aspects relative to their industry (See Figure 4.3, SIGNIFICANT ASPECTS IDENTIFIED). A low confidence level however indicates that there is a considerable variation within each group, making it difficult to claim significance.

Discussion

Product design is responsible for between 65% and 90% of the total impact of a product. It is accountable for the choice of materials, the product’s energy consumption, and its recyclebility.

ISO 14001 clearly specifies that environmental aspects of an organization’s activities, products and services is defined by what it “can control and over which it can be expected to have an influence[22].” European accreditation requirements reiterate this by specifying that the scope must be specific to the site, under clearly defined management, and that significant aspects of the EMS can lie with “suppliers, customers or related organizations which create additional environmental aspects for the organization[23]”.

American accreditation requirements give virtually no guidance as to scope of registration other than stipulating it should be appropriate (and accurate[24] ) and refers to ISO 14010 and 14011[25][26]. Lack of clear accreditation by American accreditation body has led to Group 1 registrar practices which vary greatly in their ability to capture environmental impacts that the organization ought to have influence over. This allows facilities to assert that they can narrowly define the scope of certification, eliminating many significant impacts of products, process and services that the organization undergoing certification has influence over.

3a CONTINUAL IMPROVEMENT

The ISO 14001 standard of 1996 developed a compromising position between European and American opinions on how to measure continual improvement: via impact reduction or system improvements. ISO 14001 defines environmental performance as “measurable results of the environmental management system, related to an organization’s control of its environmental aspects, based on its environmental policy, objectives and targets."[27] The standard further defines environmental targets as “detailed performance requirement, quantified where practicable, applicable to the organizations or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.”[28] IAF took this into account when carefully wording future IAF requirements regarding continual improvement.

Accreditation requirements

Present guidelines concerning the assessment of continual improvement are not detailed by either European or American accreditation requirements.

Future IAF guidance however, will require that the organization stipulate the “means” for continual improvement and that the registrar assesses and insure that the procedures are sound and adhered to. To achieve this the IAF requirements stipulate that the registrar “shall identify inconsistencies between these means and the organization’s own policy, objectives, targets, processes and results."[29] “Sound” in this context is the judgment by the registrar’s competent auditor that the organization’s procedures will and are attaining the organization’s policy, objectives and targets relative to the organization’s nature, scale and environmental impacts of its activities, products or services. “Means” refers to the mechanisms by which the organization intends to attain continual improvement and its metrics used to measure its performance. The IAF guidelines are careful not to stipulate that these mechanisms for continuous improvement must entail either reductions in adverse impacts or improvements in system performance.

American accreditation requirements do not address this issue.

Registrar practices

Group 2 and Group 3 registrars were generally found to be closer to implementing the future European requirement than Group 1 registrars (see Figure 4.1, Continual Improvement).

Three of the nine registrars were found to have addressed this area. Two Group 3 registrars stated that continual improvement be found in both system and environmental performance. One Group 2 registrar was found to have implemented the specific future European requirement that requires that the organization stipulate the means for continuous improvement.

Environmental performance characteristics

Sixty-four percent of the organizations registered by Group 3 registrars measured continuous improvement in terms of environmental performance (meeting objectives and targets). Organizations registered by Group 2 as well as Group 1 registrars were roughly split 50/50 between measuring continuous improvement by system improvement and by environmental performance.

As previously mentioned, the ISO 14001 standard does not differentiate between measuring continuous improvement by improvements in the environmental management system (system performance improvements) or in environmental performance from setting and meeting objectives and targets for environmental impact reductions (environmental performance improvements). Practically however, measuring the environmental performance through its reduction in impacts has a greater effect than measuring its system efficiency. For example, a mandate to measure and quantifiably reduced toxins emitted per unit produced will more directly achieve environmental improvement than measuring the efficiency in which environmental audits are performed. Consequently, higher points were awarded to those organizations that measure continuous improvement through environmental performance (reductions in impact) than organizations that measure system performance.

Organizations registered by Group 3 had a 25% and 26% higher average score than Group 1 or Group 2 registrars respectively in viewing continuous improvement to be measured through meeting objectives and targets (see Figure 4.3, CONTINUAL IMPROVEMENT). Because performance orientated accreditation requirements for continual improvement are not yet established, this result would suggest that the European mind-set towards measuring continuous improvement through environmental performance has a positive influence in European based, American accredited (locally) registrars emphasizing continuous improvement through environmental performance of objectives and targets.

The following is a breakdown of how the organizations scored in the sub-categories which compose the ”overall objectives and targets” category (see Figure 4.3 column groups 3-7).

Objectives

This metric measures the organization’s level of aggressiveness in selecting goals that attain large gains in environmental impact reduction. Organizations registered by Group 3 registrars had an 8% and 19% higher score in significant objectives chosen than organization registered by Group 2 registrars and Group 1 registrars respectively (see Figure 4.3-OBJECTIVES). This would suggest that the European mind-set regarding measuring continuous improvement through setting sound objectives of environmental performance has a strong positively influence concerning more aggressive environmental objectives than American mind-set.

Targets

This indicator measures the organization’s level of aggressiveness in setting percentage improvement targets for their objectives. There was no significant difference found between organizations certified by American or European accredited or based registrars due to a high variation in their client organization’s level of aggressiveness (see Figure 4.3-TARGETS).

Indicators

This metric measures the organization’s use of normalized indicators to measure the progress of the objectives set. Normalized indicators are much more accurate in measuring improvements in objectives than overall quantity indicators. They eliminate other variables, such as reduction in production or employee count, which can cloud the actual level of improvement. Organizations registered by Group 3 registrars were found to have a significant 6% and 16% higher score in the use of normalized indices used to measure objectives than Group 1 and Group 2 registrars respectively (see Figure 4.3-INDICATORS). This would again suggest that European mind-set regarding measuring continuous improvement through sound environmental performance indicators has a strong positively influence concerning the use of normalized indicators.

Target attainment

This indicator measures the organization’s success in attaining the target set for the objective. Organizations registered by Group 1 registrars were found to have a reasonably certain 16% and 26% higher score in meeting or exceeding targets established than Group 3 and Group 2 registrars respectively (see Figure 4.3-TARGET ATTAINMENT). This would suggest that American registrars emphasize to their organizations that attainment of target is the means they use to verify continuous improvement. Thus could result in one of two situations: 1) Group 1 organizations far surpass their aggressive target level on comparably aggressive objectives measured by normalized data or 2) Group 1 organizations set relatively easy targets of less aggressive objectives measured by un-normalized data in order to assure attaining their target and showing continual improvement.

Analysis of data shows that group 1 organizations have generally less aggressive objectives and use less normalized data. Analysis of target aggressiveness between groups does not give statistically viable results due to the high standard deviation. Two of the tree pieces of evidence suggest that the later situation is the likelier cause for attaining higher target attainment.

Overall

Organizations which held certification by Group 3 registrars scored 3% to 7% higher in overall performance in objectives and targets then Group 1 or Group 2 registrars respectively (see Figure 4.3-OBJECTIVES AND TARGETS TOTAL).

Discussion

Analysis of the data shows that the three registrars (all of which are European accreditation or based) who either require continual improvement in environmental performance or the means of achievement to be stipulated; have also the certified organizations who had obtained three of the four highest scores in overall objectives and targets. This indicates that organizations who specifically address how continual improvement will be met, choose to do so by using measurable terms of environmental performance with objectives and targets rather than the more indirect and bureaucratic indicators of system improvements.

Accreditation requirements that do no require the organization to address how continual improvement will be achieved miss the opportunity for the their registrars and consequently their client organizations to re-address this matter pro-actively.

If the requirement that means for continuous improvement is to be stipulated and judged for soundness by a competent auditor would be required of registrars, more aggressive objectives, targets and indicators would be the expected result. This would enhance the environment performance of the certified facility and the credibility of the overall system.

3b. PREVENTION OF POLLUTION

ISO 14001 standard defined prevention of pollution broad to encompass both camps: Prevention of pollution by best available technology or through control, reduce and recycle philosophies. It became the “use of process, practices, materials or products that avoid, reduce or control pollution, which may include recycling, treatment, process changes, control mechanism, efficient use of resources and material substitution." The practical result of which allows organizations to define pollution prevention via either the more aggressive P2 hierarchy of 1-control, 2-reduce, 3-recycle or the less aggressive end-of-pipe treatment.

Accreditation requirements

Similar to continual improvement, present guidelines on how to assess prevention of pollution are not detailed by either European or American accreditation requirements. Future European guidance however, will require that “means for prevention of pollution be stipulated and that the registrar shall assess and insure that they are sound and adhered to and to identify inconsistencies between these measures and the organization’s policy, objectives, targets, processes and results."[30] Future American accreditation requirements do not address this issue.

Registrar practice

Only 1 of 9 registrars was found to have presently implemented the future European requirement requiring their clients to stipulate the means by which to show commitment to prevention of pollution..

Environmental performance characteristics

The ISO 14001 standard does not differentiate between defining pollution prevention by “end of pipe” reductions in regulated emission or by, for example, the P2 pollution prevention hierarchy of reduce, re-use, or recycle. It is generally agreed however, that the P2 hierarchy is more likely to get greater long term reductions in environmental impact than “end of pipe” reductions (Nash & Erhenfeld 1997; Semiconductor Industry Association 1997). Seventy-four percent of the organizations certified by Group 3 registrars consider those commitments to pollution prevention to mean reduce, re-use or recycle. This compared to only thirty-six percent of organizations certified by Group 2 registrars and sixteen percent of organizations certified by Group 1, who view that commitment for pollution prevention is done by the reduce, reuse or recycle approach. Thus, organizations certified by Group 3 registrars had a 37% and 49% higher average score than organizations certified by Group 2 or Group 1 registrars respectively in defining pollution prevention by the pollution prevention hierarchy (see Figure 4.3, POLLUTION PREVENTION).

Analysis of the data reveals that the single registrar who requires that organizations define prevention of pollution with regard towards its specific aspects and measure progress also has certified organizations who had the highest Pollution Prevention score.

Discussion

The results infer that organization who specifically addresses how pollution prevention will be addressed chose to do so by the P2 philosophy of reducing material consumption through recycle, reduce programs rather than through programs for the control of end-of-pipe regulated pollutants. Because pollution prevention requirements are not yet established, the result would suggest that the European perspective has a positive influence regarding influencing the characterization of pollution prevention through the reduce, re-use, recycle perspective.

Accreditation requirements that do no require the organization to address how pollution prevention will be achieved therefore miss the opportunity for the their registrars and consequently their client organizations to re-address this matter pro-actively.

If the requirement that means for pollution prevention is to be stipulated and judged for soundness by a competent auditor becomes a requirement for all registrars, more organizations would pro-actively utilize the P2 hierarchy.. This would likewise enhance the environment performance of the certified facility and the credibility of the overall system.

4 LEGAL COMPLIANCE

ISO 14001 asks that the organization make a commitment to legal compliance[31], that procedures are established in order to be aware of the organization’s legal requirements[32], that legal compliance is considered when establishing objectives and targets[33], that compliance to these requirements are documented[34] and corrective actions recorded.[35]

A straight forward way to verify that the organization is aware of its legal requirements, that compliance is documented and corrective action taken is to review internal compliance audits of the organization. A legal situation has arisen however, particular to the US, from organizations wanting to keep confidential the findings from these internal compliance audits by invoking that the audits are client-privileged and not open to registrar assessment.

Accreditation requirements

Both American and European accreditation requirements reiterate legal compliance from within the standard, and point out that certification to the EMS can be recommended even if non-compliance(s) to legal requirements are discovered during the audit, provided that acceptable corrective actions are taken to correct the problem.[36]

American accreditation requirements further clarify however, the need for the registrar to review data on compliance[37]. Proposed future American accreditation requirements add that “affirmative statements submitted by the organization to the registration body are not sufficient for [confirming compliance to legal requirements].[38]

European accreditation requirements have not clarified assessment of legal compliance to this detail.

Registrar practices

Registrar practices vary on how each verifies compliance to legal requirements. The majority of Group 1 and Group 3 registrars were generally found to require a review of the organization’s internal compliance audit. This was not the case with Group 2 registrars, whose procedures would tend to accept a client-privilege statement from the organization and a review of the qualifications of the compliance assessment team and the findings from the internal audit. This approach does not allow a review of what regulations were audited (see Figure 4.1, Legal Compliance). As evidenced by the low confidence level of only 36% however, there is a wide variation in each of the groups. Thus it is difficult to draw any strong inference between accreditation requirements and registrar practice.

Environmental Performance Characteristics

Likewise, a high variability in the organization’s response to its tracking of and success in legal compliance (confidence level of 13%) makes it difficult to draw an inference between registrar practice and the organization’s environmental performance regarding tracking and success in legal compliance (see FIG 4.3, COMPLIANCE AND INCIDENCE).

Discussion

Assurance of legal compliance is considered a very important aspect by certain stakeholders, particularly state and local regulatory agencies who are considering pilots which leverage ISO 14001’s commitment to legal compliance (clause 4.2) in order to reduce the regulatory inspection burden for facilities having ISO 14001 registration (Villani, 1999). The high variability of registrar’s assessment procedures concerning accepting affirmative statements that the organization is in compliance with all appropriate legal regulation is possibly why ANSI-RAB has specifically stipulated that this is not allowed in its most recent draft requirements E3.2.

Relationships between regulatory agencies and industry are more co-operative in Europe due in part to a different system of civil law that does not create a fear of citizen lawsuit so common in the US (Hartnett 1992). Review of European organization’s internal compliance audits by registrars is the normal procedure to verify commitment to compliance and is a likely reason why European accreditation requirements have not strongly addressed a problem that does not exist within the European continent. Non the less, 70% of the organizations holding ISO 14001 registrations are certified by European based or accredited registrars. It therefore may be important for the European accreditation bodies to address this requirement more directly for those countries where different regulatory relationships and legal systems and concerns exist. This would allow all registrars operating in the US a solid means and rational to “verify that the organization has evaluated its legal and regulatory compliance and can show that action has been taken for non-compliance.”[39]

5 DETERMINING AUDIT DAYS FOR ASSESSMENT, RE-CERTIFICATION AND SURVEILLANCE

To become certified, an organization must undergo a third party assessment of their procedures and facility. Additionally, periodic surveillances need to be conducted. Neither ISO 14001, 14010, 14011, 14012 nor ISO 66 gives guidance regarding how many days a registrar should be used for calculating the number of assessment nor surveillance audit days. IAF guidance to ISO 66 stipulates several items the registrar should consider when determining audit duration. European requirements do not directly give guidance regarding what to consider for assessment of a single site but do list considerations a registrar should take into account to determine the number of surveillance audit days. All guidelines are open to much interpretation and variation between registrars.

Accreditation requirements

Registration

Presently, neither European nor American accreditation bodies have stipulated requirements for the number of audit days to be used for certification and re-certification. Future IAF guidance however, stipulates specific areas to be reviewed to determine the number of audit days.[40] In particular, the following factors are to be taken into account:

1. results of internal audits

2. results of management review

3. maturity of the system

4. any existing knowledge of the organization

5. the size of the organization

6. the complexity of the organization

7. any shift work

8. varies in working practices

9. repetitiveness of functions

10. variation in activities undertaken

11. the significance and extent of the aspects

12. potential interaction with sensitive environments(s)

13. differing legal requirements

14. the views of interest parties.

To reduce unfair competition between registrars and insure a certain minimum level of assessment time at the organization, RvA has stipulated the minimum number of audit days to be used for assessments. It is based on the organization’s number of employees and the level of environmental hazard.

Surveillance

Present European accreditation guidelines stipulate specific elements that should be assessed to estimate surveillance audit days.[41] Specifically, minimum annual surveillance should include: 1) internal audits, 2) management review, 3) preventative and corrective action. 4) communication s from external interested parties, 5) changes to documentation system, 6) area subject to change, 7) selected elements of the standard and 8) other areas as appropriate

In addition, European accreditation guidelines require that surveillance include certain effectiveness, managerial and functionality ’considerations’.[42] In particular:

1. the effectiveness of the EMS in achieving the objectives of the policy

2. an interview with EMS management

3. the functioning of procedures which respond to communications from external parties

4. the functioning of procedures that review compliance with relevant regs.

5. progress of enhancing the EMS to achieve improvements in overall environmental performance in line with policy

6. follow-up of internal audits

7. action taken in response to complaints

RvA has stipulated minimum number of audit days to be used during the surveillance cycle of an organization’s EMS, based upon its size and environmental hazard.

American accreditation requirements do not give similar guidance in the above areas, but only require each element to be audited once per 3 years[43], and that surveillances and re-certification programs “should be consistent with those concerning initial registration of the organization’s EMS”.[44]

Registrar practices

With a confidence level of 71%, notable differences exist amongst registrar practices in quoting audit days for certification (see Fig. 4.1, Determining Audit days for certification and surveillance). The registrar’s assessment of audit and surveillance days were compared using RvA recommendations of audit days for 3 ranges of aspect complexity and for an organization’s employee count of 10, 30, 100, 500 and 2000. Group 2 registrars quoted considerably higher number of audit days for certification, up to 40% higher than Group 3 and 15% higher than Group 1. There was little difference between number of surveillance days quoted between Group 1 and Group 3 registrars; both had lower surveillance estimates than the Group 2 registrars.

Environmental performance characteristics

The organizational survey did not uncover any direct inference that number of auditor days directly influenced environmental performance characteristics. However, the second most frequently cited value organization’s received from their registrar is from the surveillance. Client organizations rate surveillances to be one of the highest values the registrar offers, particularly in discovering “opportunities for improvement” (through corrective action request of non-compliance to ISO 14001) and in maintaining a heightened awareness of EMS implementation and maintenance.

Discussion

In the competitive market of certification, registrars face ceaseless pressure to reduce the price of their service. The typical response is to reduce the number of audit days used for certification. Without clear guidelines to maintain a certain level of assessment time, competition can quickly compromise a registrar’s auditor quotation process in order to “get the business." This situation can be seen in the reduced amount of auditing days quoted by non-RvA accredited registrars (Fig. 4.1, Determining Audit days for certification and surveillance). It is a clear argument that guidelines which merely specify assessment and surveillance considerations, as is done with present European accreditation requirements, or are not addressed at all, as done with American accreditation requirements, are inadequate to prevent the compromising of the number of audit days used for assessment and surveillance. The result of which will eventually bring about a similar situation such as is transpiring in Asia today. In Taiwan for example, a Taiwanese company can be certified by a single auditor in one day (Curran 1999, Roht-Arriaza 1997). RvA has recognized this situation and has instituted a matrix table that calculates the number of assessment and surveillance days for specific industry, environmental risk, and employee count. This acts to maintain a high level of integrity for ISO 14001 certification. American and other European accreditation bodies who do not presently implement a specific auditor day formula would do well to join RvA in order to earn stakeholder trust and maintain the credibility of the ISO 14001 certification process.

6 ENVIRONMENTAL COMPETENCY AND ONGOING JOB TRAINING

Accreditation requirements

European accreditation guidelines require registrars to:

1. Ensure that auditors are competent in assessing the organization’s ability to assess and manage its environmental aspects and impacts.[45]

2. Ensure there is a competent system capable of verifying the accuracy of the organization’s environmental aspects as stated on its contract application form.[46]

3. Insure that the registrar has the competency to insure that “typical environmental aspects and associated impacts, arising from the complete range of the organization’s activities, correspond to those identified in the contract."[47]

4. Ensure that the final decision concerning the granting or withdrawal of certificates is made by an environmentally competent individual.[48].

5. Collectively, team needs experience, training, and be up to date on:

· techniques to reduce harmful environmental impacts and their application

· performance of analysis of environmental aspects and associated impacts.[49]

American accreditation requirements do not contain explicit requirements concerning any of the above areas.[50]`[51] [52].

Registrar practices

Educational requirements for Group 1 and 2 registrars tend to be higher than Group 3 registrars. The experience level of auditors hired indicated that Group 1 and Group 2 registrars tend to be marginally higher experience requirements than Group 3 registrars. The training required to become an EMS regular and Lead auditor was relatively the same amongst all registrars.

The main difference in competency between registrar groups comes primarily from the method of assessing auditor competency. Higher points were awarded for those accreditation bodies that personally reviewed each lead auditor as to his or her industry sector competence rather than relying on a system that accepts paper documentation that professes the competency of the auditor. Consequently, registrars accredited by RvA scored higher because they require their lead auditors to have demonstrated their ability in that industry sector by a witnessed RvA audit. Thus, with a confidence level of 92%, group 2 registrars scored higher regarding auditor’s knowledge of legal, pollution control, and impacts and aspects relative to group 1 and 3 registrars, as can be seen in Figure 4.1, Environmental competency requirements

Ongoing training practices concerning auditor consistency and monitoring of assessors/experts and subcontractors are higher in group 1 registrars than group 3 and group 2 respectively (see Figure 4.2, Ongoing training)

Environmental performance characteristics

The organizational survey did not uncover any direct inference that auditor competency directly influenced environmental performance characteristics. However, the environmental competency of the registrar was found to be one of the most important values a registrar gives to an organization. Knowledge shared, thoroughness and “being tough” were the most common answers given during the open-ended survey. This was shared equally amongst organizations certified by Group 1, Group 2 and Group 3 registrars equally.

Discussion

Auditor competency is valued by ISO 14001 certified organizations, particularly in thoroughness, knowledge and maintaining resolve. European accreditation bodies require a higher level of Environmental competency in their guidelines. This leads European accredited registrars to have increased competency requirements. Increasing American accreditation body requirements for Environmental competency, particularly about environmental aspect and impact competency, would help insure that users of the ISO 14001 certified by American accredited registrars will have auditors as competent as European accredited registrars.

Having the accreditation body qualify the registrar’s lead auditors through witness audits is the reason training and competency requirements are higher for European accredited registrars. Conversations with European and American accredited registrars specifically point out that the RvA’s witnessing of lead auditors compels them to utilize auditors competent in that specific industry -- an expensive process that puts them at a disadvantage when competing against non- RvA accredited registrars.[53] ANSI-RAB practice of requiring documentation of environmental audits and letters of recommendation is not as rigorous of method. It “has a reputation for stretching the truth in order to qualify on paper as an environmental auditor.”[54]

Within the span of this study, cost and registrar pressure have caused RvA to reconsider this witnessed qualification program and instead consider a plan to sample witness lead auditors that have been approved by a registrar. This new program is not likely to encourage the same level of competency as accreditation witnessed qualified lead. There are many variables that act to diffuse this new method, including the registrar’s willingness for risk, their ability to influence auditors available for a witness audit, and the ramification of failure to meet the requirement.

Thus, world-wide adoption of the practice of requiring a witnessed lead auditor for assessments by accreditation bodies would help to insure ISO 14001 certified organizations have a level playing field of equally competent auditors.

7 ASPECT AND IMPACT ASSESSMENT

Accreditation requirements

Assessment of aspects and their impacts are emphasized more within European accreditation requirements than within American accreditation requirements. ISO 66 states that “the audit team shall assess the EMS of the organization covered by the defined scope against all applicable registrar requirements." European accreditation requirements have over 6 pages related to assessment criteria. These serve to clarify how registrars should assess an organization. Several of these pages concern the assessment and verification of impacts and aspects. American accreditation requirements, on the other hand, have one 3 line paragraph. Consequently there are several areas that are not addressed by the American accreditation body.

The following is a breakdown of the differences in aspect and impact assessment between American and European accreditation requirements, their associated registrar practices, organizational environmental performance characteristics and a discussion of each. These differences are characterized by requirements associated with:

A) Environmental competency

B) Definition of significance

C) Verification of stated aspects and impacts during contract review

D) Management of all significant aspects

E) Identification of aspects, their impacts, and determination of their significance.

As is often the case, different accreditation practices affect registrar and organizational practices in more than one area. Accreditation differences and resulting influences regarding “Environmental competency requirements for aspects and impacts assessment (A)” are covered in section 6, Environmental Competence and Ongoing Job Training. Likewise, accreditation differences and resulting influences regarding “Definition of significance of aspects and impacts (B)” are covered in section 2-Scope of Registration.

Registrar practices

Overall

Registrar’s responses among these accreditation requirement differences were rated against benchmark criteria. The results from the combined scores give a higher overall score to group 2 registrars, followed by group 3 registrars then by group 1 registrars (See Figure 4.2, Aspects and impacts assessment). The following discusses the components which make up this overall score.

A & B Environmental competency and Definition of significance

See Section 6 (Environmental competency and Ongoing Job Training) for discussions regarding A--Environmental Competency and section 2 (Scope of registration) for discussion concerning B--Definition of significance.

C. Verification of stated aspects and impacts during contract review

Accreditation requirements

Contract review is the process that the registrar uses to understand a potential client’s scope of EMS activity. Registrars typically send out a rather lengthy application form for the applicant to fill out. It includes questions regarding the size and complexity of the organization and the environmental aspects the company has identified. The registrar reviews this information to assess their ability to audit the organization, as well as to estimate the number of auditor days, expertise needed and price for registration assessment. European accreditation guidelines specifically require that, during this contract review and prior to any on-site assessment or acceptance of the contact, the registrar “confirms that the organization’s assessment of aspects and their impacts correspond to typical aspects and its impacts arising from the complete range of the organization’s activities."[55] The purpose of which is to be able to schedule appropriate auditors to the assessment.

No such guidelines are given by American accreditation requirements.

Registrar practices

Generally, all registrars confirmed that the organization’s assessment of aspects and their impacts correspond to typical aspects and its impacts arising from the complete range of the organization’s activities during the first stage of the audit.

Discussion

Guidelines which require that the audit team selected for the assessment be suitably trained for impact and aspect knowledge of that particular industry sector insures that the appropriate team is placed on the audit. Without such requirements, verification of aspects and impacts during the first stage of an audit could not be guaranteed. This is because the system does not prevent selecting an audit team that does not have appropriate experience with the particular industry. American accreditation requirements do not specify guidance on assessment of aspects and impacts during contract review are done, consequently, it can not be assured that the team can confirm the organization’s assessment of impact and aspects during the first stage audit. European accreditation requirements ask that this is done during contract review, not during first stage. However, evidence that European accredited registrars were doing this could not be found. This indicates that this particular European accreditation requirement is not being implemented.

D. Management of all significant aspects

Accreditation requirements

European accreditation requirements require all aspects deemed significant by the organization be managed through programs, operational controls or further investigation.[56] Although some may consider this clause outside the scope of the ISO 14001 standard, subsequent conversations by RvA[57] and IAF[58] officials confirm that this clause has been long established within European and IAF guidelines, and although contentious, is within the scope of ISO 14001 standard and its assessment criteria.

No such guidelines are given by American accreditation requirements.

Registrar practices

EA-7/02 requires that all aspects deemed significant need to be managed within the EMS, either through objectives and targets, or programs or control technology. All of Group 3 registrars and 75% of Group 2 registrars confirmed this as their practice. Group 1 registrars however either said it was based on policy or that it was not necessary to control all aspects deemed significant.

Discussion

European influence, either by accreditation or home base influence, has clearly resulted in registrar procedures which assure that significant impacts are either being controlled, undergoing a systematic reduction through objectives and targets or are being studied. This attains the stated intent of ISO 14001 to “support environmental protection and prevention of pollution"[59] through a systematic method of achieving improvements in overall environmental performance. Inclusion of this statement by American accreditation requirements will help guide registrars to insure that the above is being met without going beyond ISO 14001’s requirements.

E. Identification of aspects, their impacts and determination of their significance

Accreditation requirements

European accreditation guidelines specifically require the registrar to both insure that the procedure for identifying aspects and their impacts and that the criteria for determining significance is sound. These guidelines further clarify that it is up to the organization to define the criteria by which environmental aspects and their associated impacts are identified as significant and to develop procedures for doing this, but for the registrar to raise objections if the procedure or the results of their application is not consistent with the organization’s policy, objectives and targets.[60]

Registrar practices

Part 1: Assessment of sound aspect and impact review methodology

The survey asked how the registrar gained confidence that the procedure used by the client to identify environmental aspects and impacts were sound.[61] Most registrars do this by internally generated information that identify typical industry aspects and associated impacts while using an experienced EMS auditor or technical expert. However, there was one registrar from each accreditation who judged soundness primarily by assessing the organization’s use of a team approach in its gathering and assessment of aspects and their impacts.

Part 2: Assessment of sound determination of significance

The survey asked how the registrar gains confidence that the criteria used to determine significance is sound. The majority of Group 2 registrars tend to determine soundness by applying the same methodology as the organization did. If the same conclusion is reached, then the criteria is deemed sound. These registrars used no specific internal criteria.

Group 1 and Group 3 averaged higher scores against this question, as the majority also included the use of the organization’s own policy to judge significance, and requires the use of at least regulatory and environmental risk criteria. Group 1 and 3 registrars start with this method, but also compared the organization’s determination of significant aspects to the organization’s own policy. Additionally, these registrars required, at a minimum, that regulatory and risk criteria be used to evaluate significance.

Organization’s environmental performance characteristics

Part 1: Aspect and impact review methodology

The open-ended environmental performance survey asks registered organizations what criteria were used to identify significant aspects and related impacts. Responses were then categorized and rated as to its level of thoroughness in the criteria used to identify aspects and impacts.

The average response for aspects and impacts review criteria scored 6.4. A notable difference of a 15% and 18% higher score was achieved by organizations certified by Group 2 and Group 3 registrars respectively (See Figure 4.3, ASPECT AND IMPACT REVIEW METHODOLOGY).

Part 2: Determination of significance

The open-ended environmental performance survey also asked registered organizations which aspects of the organization’s environmental review were deemed significant. Responses were categorized and then rated as to depth of analysis used when selecting criteria to determine which aspects are significant..

In identifying significant aspects relative to their industry, the average score was 6.6 points. Organization’s certified by European-influenced registrars (Group 2 and Group 3) averaged a 9% and 13% higher score respectively than Group 1 registered organizations (See Figure 4.3, SIGNIFICANT ASPECTS IDENTIFIED). A confidence level of only 44% however, indicate that there is a considerable variation within each group, making it difficult to claim significance.

Discussion

ISO 14001 itself does not give specific guidance as to how to the identify aspects and impacts, nor how to determine their significance. American accreditation requirements likewise do not give guidance on aspect and impact assessment. European accreditation guidelines however, stipulate that the registrar must insure the client organization has sound procedures for identifying aspects and their impacts as well as sound criteria for determining significance. Webster’s Encyclopedic Dictionary (1971) defines "sound" as “free from imperfection or defect, founded in truth, valid, that cannot be refuted, correct, and free from error." Thus it can be implied that the aspect/impact identification and its assessment of significance must be valid, correct, and free from error as judged by the auditor.

This European requirement continues with the stipulation that although it is up to the company to determine aspects/impacts and their significance, the registrar must raise a non conformity if there are inconsistencies between the organization’s policy, objectives and targets and procedures or their results [for identifying aspects and impacts and their significance]. In other words, the organizations must be right as judged by the audit team and relative to the organization’s own policy in both the methodology involved in assessing aspects and their impacts and the resulting choice of significant aspects. Note: It is important to remain clear that this topic concerns determination of significant aspects, not determination of objectives and targets. Determination of significant aspects is relative to the environment and thus must

List of tables	Page

3.1 Environmental performance characteristic assessment matrix	24
5.1 Areas where differences in registrar practice and environmental performance characteristics were found to be associated with identified differences in accreditation requirements.	68

Lists of Figures	Page

1.1 Overview of research	15
3.1 Detail influence chart of accreditation, registrar and environmental performance characteristics	21
4.1 Comparison of accredited registrar practices 1-7	28
4.2 Comparison of accredited registrar practices 8-13	28
4.3 Comparison of environmental performance characteristics of accredited registered organisations	29

	Performance category	Score Ratings for each category based on the following criteria:
1	SIGNIFICANT ASPECTS IDENTIFIED	5 = Regulatory aspects (Emission, incidences, hazardous waste, TRI (Toxic Release Inventory) chemicals) 6 = #5 plus office wastes, employee health aspects 7 = #6 plus natural resource and energy depletion, biodiversity, aspects of industrial landfill impacts 8 = #7 plus product packaging aspects 9 = #8 plus LCA analysis, product use and disposal aspects (if appropriate) 10 = # 9 plus strategic business plan aspects
2	ASPECT AND IMPACT REVIEW METHODOLOGY	5 = Use of regulatory criteria 6 = #5 and natural resource reduction criteria, global warming criteria 7 = # 6 plus use of environmental expert, interest parties criteria, bio-diversity criteria 8 = #7 plus use of non-regulated toxicological criteria 9 = # 8 plus Life cycle analysis of cradle to (cradle) 10 = #9 plus product use criteria, integrated into business strategy e.g. Interface, Electrolux
3	OBJECTIVES	5 = Deal with reduction of regulated material, recycling of office refuse 6 = #5 plus deal with identified significant impacts concerning energy or water or natural resources 7 = #6 plus deals with identified significant impacts concerning recycling of industrial waste 8 = #7 plus “zero waste” objectives 9 = #8 plus LCA objectives (if appropriate) 10 = #9 plus Design for Environment objectives (if appropriate)
4	TARGETS	Certified 1.5 years or less 5 = no goals established 6 = 5-10% 7 = 11-15% 8 = 16-25% 9 = 26-49% 10 = >50%	Certified 1.5 years or more 5 = 0-5% 6 = 6-10% 7 = 11-15% 8 = 16-20% 9 = 21-25% 10 = >25%
5	INDICATORS	5 = Feasibility study 6 = non normalized indicators of achievement 7.5 = mix of normalized and non normalized indicators of achievement 9 = normalized indicators of achievement
6	TARGET ATTAINMENT	1 = objective dropped 2 = no target(s) 3 = met target(s)+/- 10% 4 = exceed target(s) by 15-49% 5 = exceed target(s)>50%
7	TOTAL OBJECTIVE AND TARGET PERFORMANCE	Total based on categories 3-6
8	CONTINUOUS IMPROVEMENT	1 = system improvements only 2 = procedure requires system improvements 3 = environmental performance attained through objective and targets 4 = procedures detail environmental and system improvement
9	POLLUTION PREVENTION	1 = end-of-pipe regulated pollution reductions 2 = procedure details end-of-pipe pollution requirements 3 = reduce material consumption through recycle, reduce programs 4 = procedure specify #4
10	LEGAL COMPLIANCE AND INCIDENCES	1 = Some NOVs (Notice of Violation from State or Fed.) incidences 2 = No NOVs 3 = No NOVs, Compliance target specified and measured
11	Overall Total Value
12	Registrar value?
13	Certificate value?

2 Research question addressed

3 Research Methodology

4 Analysis and results

5 Summary