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Re: P2 and ISO 14000

Since I do some work in both the P2 and 14000 areas I'll throw in my two

At the insistence of the U.S. delegation to the ISO negotiating committee,
the final 14001 standard references "prevention of pollution" and not
"pollution prevention."  EPA objected strongly to this wording because POP
is not limited to source reduction, but also includes recycling and waste
treatment/disposal.  Here is the definition of POP from the 14001 standard:

3.13 Prevention of Pollution
use of processes, practices, materials or products that avoid, reduce or
control pollution, which may include recycling, treatment, process changes,
control mechanisms, efficient use of resources and material substitution.

In the standard itself, POP is mentioned only under 4.2 Environmental
Policy, which requires top management to establish an environmental policy.
 Among other things, the standard specifies that the policy must include a
commitment to prevention of pollution.

While this may sound halfhearted (it's in the policy -- so what?), the
appearance of such a commitment in the environmental policy is very
significant.  (In fact, everything that goes in to the policy has enormous
implications, a point not widely recognized by facilities first starting
out to develop an EMS).  First, the policy must be signed by the top
management of the organization, and management is held responsible (by the
14001 auditors) for demonstrating adherence to the environmental policy. In
practice, this means that the facility must demonstrate that they have a
systematic POP program in place.  The program must be documented, and
employees must be trained on it.  

The POP commitment in the policy may drive other parts of the EMS as well.
When evaluating environmental aspects ("elements of an organization's
activities, products or services that can interact with the environment")
to identify those that are "significant", the facility may frequently
include in their criteria "any aspects that relate to commitments made in
the environmental policy."  In this way, aspects amenable to POP may be
identified as significant aspects. Once an aspect is identified as
significant, the facility must establish objectives, targets, and
performance measures for the aspect, and provide necessary training to
employees who are involved in that part of the operation.  

In summary, 14001 requires a commitment to POP in the environmental policy,
and this has significant implications for the facility.  At present,
however, POP includes treatment.  This significantly weakens the ability of
14001 to encourage further P2 efforts in industry.  For organizations that
do practice P2, the EMS can provide the framework for driving P2 throughout
the company.  Smart environmental managers with a commitment to P2 are
recognizing this and using it to make a bigger push.

It is also worth noting that this "deficiency" in the 14001 standard is the
subject of considerable debate right now, and it is widely believed that
efforts will be made to expand the discussion of P2/POP during the next
revision of the standard (all ISO standards are subject to review and
revision every 5 years), which will take place in 2001.

Also, in response to Marv Fleishman who suggested P2 would be implied by
the requirement for continuous improvement, the improvement they are
looking for is in the system, not performance per se.  By way of example,
say the company makes a commitment to compliance in their environmental
policy, and implements a compliance management system to demonstrate this
commitment.  From an auditing standpoint, what the auditors want to see is
not necessarily a perfect compliance record.  Rather, should there be a
noncompliance episode, they want to see that a system was in place that
detected the noncompliance, reported it, and corrected it.  Also, the
facility should be able to show that they then analyzed the problem to
determine the root cause and made adjustments.  If an audit finds that this
system is deficient, what they will be looking for the next time is
improvements to the system.  

 ______ _____   _____
|  ____|  __ \ / ____| 		Jeff Cantin
| |__  | |__) | |  __  		ERG, Inc.
Eastern Research Group 		www.erg.com
| |____| | \ \| |__| | 		110 Hartwell Ave.
|______|_|  \_\\_____| 		Lexington, MA 02173