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RE: FW: Evaluation tool for EMS



Thanks for shedding more light on the subject, Bob.  My question was not a
casual one; 
back in 1995-6 my colleagues Edna Besnainou, Marina Skumanich & I did an
evaluation 
of the role of EMS systems in policy development (conducted under a grant
from EPA Region 10
Office of Innovation), resulting in a report that unfortunately had about as
much impact on the P2 community as a stray neutrino.  
Nonetheless, I think there were a few valid observations entombed in that
now dust-laden report.

We did attempt to address the issue of whether an EMS actually CAUSED
environemntal improvement, 
or could even be linked to it statistically.  Since we did not at that time
have the wealth of good data collected since by the MSWG , 
I decided to reason by analogy, looking at the research literature for ISO
9000.
At the time, the few studies I found which addressed the issue in a robust
way all came up with 
the same conclusion -- there was no statistical evidence for the notion that
implementation of ISO 9000 
led to improved product quality.  (I should provide a caveat that these
studies were restricted in scope to 
narrow industry sectors, including software development, so it's possible to
read TOO much into 
this..).  Given the strong parallels between the ISO 14000 and 9000
standards at the time, 
one could make the prediction (as I did in the study) that a similar
"disconnect" would exist 
between ISO 14000 and environmental quality improvements.  I suspect that
even once the MSWG has 
collected additional data, it may be somewhat difficult to prove a causal
relationship, even if a statistical
correlation can be demonstrated. 

I don't think that any of this negates the value of implementing a well
considered EMS.  And having looked at RTI's 
EMS-Plus application, I think it could be instructive to those who are not
familiar with some of the potential 
shortcomings of a "content-free" EMS.  

SB

Scott Butner (butner@battelle.org) 
Senior Research Scientist, Environmental Technology Division
Pacific Northwest National Laboratory
MS K8-03
PO Box 999, Richland, WA  99352
(509)-372-4946 voice/(509)-372-4995 fax
http://www.chemalliance.org/




> -----Original Message-----
> From:	Robert Pojasek [SMTP:rpojasek@sprynet.com]
> Sent:	Wednesday, October 11, 2000 12:15 PM
> To:	p2tech@great-lakes.net
> Subject:	Fwd: FW: Evaluation tool for EMS
> 
> RTI should check out the web site for the MSWG.  They admit in papers
> written by one of the project's sponsors that they cannot find a link to
> environmental improvement and that it will take at least three more years
> before they can have enough data to see one.  They are working with the
> "creme de la creme" of the ISO 14001 cases here.  Scott is right on with
> his question!  Many companies only do ISO 14001 because someone is making
> them do it.  They only do what is required of them to do - nothing more.
> Of course, there are exceptions to this rule.  ISO 14001 is NOT
> performance-based.  People need to buy a copy of ISO 14001 and read the
> requirements.  They should not be confused with what different people
> write
> about ISO 14001.  It has much discretion and everyone implements it
> differently.  However, if the best cases cannot see clear environmental
> benefits after two years of study, I think there might be a problem here.
> The Mexican government (PROFEPA) has ignored ISO 14001 in their Voluntary
> Environmental Audit Program because it does NOT guarentee compliance.  I
> have attended talks in Canada where practitioners have admitted that ISO
> 14001 has failed to meet its promise.  First it has been the environmental
> folks doing ISO 14001 for the rest of the organization.  Its
> implementation
> misses the following key items:  concern and awareness; management
> commitment; robust planning; integration of external stakeholders; and
> focus on performance improvement.  ISO 14001 would fail its own test.  It
> has NOT continously improved itself since it has been published.  Even ISO
> 9000 has been rewritten to make continuous improvement mandatory for
> certification - it is called ISO 9000-2000.
> 
> I hope RTI has not biased their system in this regard.  It will be
> interesting to hear what they come up with.  By the way, the Green Zia
> program in New Mexico is a performance based program for setting up an
> EMS.
>  It overcomes all the issues raised in Canada and Mexico.  ISO 14001 is a
> good first step towards getting a good Green Zia score, but is nowhere
> near
> sufficient to get you a top award in their program.  Pat Gallagher has
> some
> GREAT information on the program on their web site at
> <http://www.nmenv.state.nm.us/>  Scroll down to Special Events and
> Programs.  Maybe we should be spending our time looking at this program if
> we are interested in a PREVENTION_BASED APPROACH.  Remember how ISO 14001
> defines "The Prevention of Pollution" to include end-of-pipe wonderment.
> Green Zia does not.  Maybe we will have some people argue for EMAS with
> its
> bit of performance based application.  This could be fun.
> 
> BOB Pojasek
>