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RE: EMS Evaluation (response to Bob Minicucci)






I apologize if I have misrepresented anyone, I try to avoid that.  Also, and
quite importantly to someone with a name like mine, I apologize for
mis-spelling the name.

And now, to continue an intersting discussion:

I find the reasoning of using ISO 9000 to illuminate ISO 14000 'behavior'
interesting.  I'll want to ponder the validity of that before I personally
sign  on to that.  I note that a correlation was found between increased
product quality and use of ISO 9000; this is a hopeful sign.

My own opinion is that it is not strictly necessary to show a causal
relationship if a reliable correlation can be shown.  In this I am firmly an
engineer and not a scientist, so I'll sign off quite formally,

Robert P. Minicucci II, PE
NH Dept. of Environmental Services
6 Hazen Drive,
Concord, NH 03301
603-271-2941

-----Original Message-----
From: Butner, Robert S [mailto:butner@BATTELLE.ORG]
Sent: Friday, October 13, 2000 11:08 AM
To: 'p2tech@great-lakes.net'
Cc: 'rminicucci@des.state.nh.us'; 'Malkin Weber, Melissa'
Subject: RE: EMS Evaluation (response to Bob Minicucci)


In his recent rejoinder to the discussion of EMS standards on P2TECH, Bob
Minicucci (rminicucci@des.state.nh.us) wrote, in part:

 > Response to Mr. Buttner:  I and MSWG would be interested in what he''s
 > "...found in the research (that) indicates that creation of an EMS has no
 > demonstrable cause-effect relationship to a firm's environmental
 > performance..."  I submit that the question has not yet been answered
 > either yes or no.  Mr Buttner implies that the answer has been
 > demonstrated to be no.  I'd like more information on that.

Not having a particular axe to grind on this issue (I consider myself
neither "pro" EMS/ISO14000 or "anti" EMS/ISO14000) I am happy to
oblige.  However, I should first set the record straight on Mr. Minicucci's
"excerpt" from my message.  The lines quoted above actually do
NOT accurately reflect my statements and in fact are not taken from either
of my two recent postings on the subject.  They apparently reflect an
attempt to paraphrase my comments but I think have missed my point.  What I
HAVE claimed, and I think with some justification, is that

	"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. "
	message to P2TECH, posted 10/11/2000

My claims about the research literature in fact specifically state that not
enough data has been collected yet (remember these findings were written in
a report
that we began researching in 1996, only a short time following the formal
adoption of the ISO standard).  For that reason we elected to look at ISO
9000 studies to determine if any solid linkage could be established between
ISO 9000 registration (also a procedural-based standard with strong
structural parallels to ISO 14000) and its objective -- i.e., product
quality.    Our findings at the time indicated that in fact, there was
little or no evidence demonstrating a causal linkage.  However, I have
excerpted the entire section of my report dealing with that issue, and
attached it below so that those still paying attention to this message
thread can read the original comment in context.  Incidentally, these same
results were included in my presentation at last year's Brooking's Institute
conference on Environmental Management Systems, so MSWG has had access to
them for some time.

But a more important issue lingers.  Lost in the confusion over what we know
or don't know about ISO 14000 and its impact on environmental performance is
the following observation from the original report:

			"The bottom line message seems to be that while the
overall effect of ISO 9000 on industry has been to promote improved product
quality, it is neither a necessary nor sufficient indicator when applied at
the level of the individual company or facility.
			
			In light of the assumed parallels between ISO 9000
and ISO 14000, this is an important finding.  Much of the policy discussion
of EMS standards has revolved around whether or not registration to an EMS
standard serves as an effective indicator of environmental performance at
the corporate or facility level.  Based on the review of ISO 9000
literature, it may be safer to conclude that widespread adoption of EMS
standards are likely to improve overall environmental performance of
industry, as contrasted to viewing EMS adoption as a meaningful indicator of
facility environmental performance. The result of such a conclusion would be
to shift emphasis from regulatory streamlining to technical assistance, and
to favor broad-based outreach and incentive efforts over demonstration and
pilot programs (which typically affect "early adopters" who tend to have
already high environmental performance).  "

			"Environmental Management Systems:  A Critical
Review of Policy Implications"
			Butner, Skumanich and Besnainou
			Report prepared for US EPA Region 10 Office of
Innovation
			02/98

Clearly (I hope), my intent was not to downplay the value of Environmental
Management Tools as instruments for environmental improvement, but to focus
the effort where it would do the most good (e.g., technical assistance as a
higher priority than regulatory flexibility).  Remember that this was
written at the time when several state agencies were examining the idea of
using registration to an EMS standard as a "proxy" indicator for
environmental performance and possible criteria for entrance into various
flex-track and fast-track regulatory schemes.   Since the time this report
was published, many of these same states have elected to rethink this at
least somewhat, trending towards more performance/outcome based approaches
like New Mexico's or Alaska's or (insert your favorite program here).   Wish
I could take credit for that -- I cannot -- but at least there seems to be
some general momentum building behind the essence of my findings.

Hope this sets the record straight, and hope that this clarification is
responsive to Bob's request.  Incidentally, this has been a great
discussion, particularly for one like myself who has been on something of a
project-imposed exile from the P2TECH community of late.  Thanks to Melissa
Malkin at RTI for precipitating it with her reposting of my note to her.

Finally, as long as I am being detail oriented for a change, Butner is
spelled with one "t" not two, for obvious reasons (or at least,  reasons
that would be obvious if you grew up with a name like Butner).  If the
family could figure out how to spell it without ANY "t"'s, we probably would
do so.  :)

For those who would like to read the original comment in its context, here's
the full excerpt dealing with causal relationships, excerpted from our
original report:

			Review of ISO 9000 literature does not support a
causal relationship between ISO 14001 and improved environmental
performance.  Much of the regulatory interest in the EMS standards is based
on a presumption that the creation, documentation and third party
certification of an environmental management system will naturally lead to
improved environmental performance.  Review of the empirical data does not
yet appear to support this presumption, which is built largely on the
argument that increased managerial attention to environmental issues (a
hard-to-dispute benefit from ISO 14001 registration) will eventually and
certainly lead to environmental improvement.
			
			In light of the short history of the standard, it is
not surprising that relatively little empirical data has been collected
relating the effect of EMS implementation to environmental performance.
However, as has been noted elsewhere in this report, the ISO 14000 standard
is similar in many respects to the ISO 9000 quality standard.  These
parallels led the author to examine the ISO 9000 literature in hopes of
documenting causal relationships between ISO 9000 and product quality.
Given the similarities between the standards, such links might be expected
to provide insight into the relationship between ISO 14000 and environmental
performance.
			
			Unfortunately, the connection between ISO 9000 and
product quality improvements does not appear to be as well documented as one
would expect, given the extensive industry experience with the standard.
In fact, a review of the literature and postings to ISO 9000 discussion
groups elicited only a small number of empirical studies of the relationship
between ISO 9000 and product quality*.  Surprisingly, none of these studies
was able to document a correlation between registration to ISO 9000, and
objective measures of product quality.
			
			While the above data do not support a direct
cause-effect relationship between registration to ISO 9000 and product
quality, few people would interpret this to mean that the ISO 9000 standard
has no role in promoting or documenting quality.  There is a large body of
anecdotal and case-study information available indicating a relationship
between conformance to the standard and improvements in quality.  And
regardless of the actual impact (or lack of impact) of the registration
process on quality at the facility level, most would agree that the presence
of the standard has reflected (and perhaps driven) an overall trends towards
higher quality of products at the industry sectoral level.  The bottom line
message seems to be that while the overall effect of ISO 9000 on industry
has been to promote improved product quality, it is neither a necessary nor
sufficient indicator when applied at the level of the individual company or
facility.
			
			In light of the assumed parallels between ISO 9000
and ISO 14000, this is an important finding.  Much of the policy discussion
of EMS standards has revolved around whether or not registration to and EMS
standard serves as an effective indicator of environmental performance at
the corporate or facility level.  Based on the review of ISO 9000
literature, it may be safer to conclude that widespread adoption of EMS
standards are likely to improve overall environmental performance of
industry, as contrasted to viewing EMS adoption as a meaningful indicator of
facility environmental performance. The result of such a conclusion would be
to shift emphasis from regulatory streamlining to technical assistance, and
to favor broad-based outreach and incentive efforts over demonstration and
pilot programs (which typically affect "early adopters" who tend to have
already high environmental performance).

			*An outstanding treatment of this topic is
available in a thesis entitled "A Review of the Empirical Research on ISO
9000," by Chris FitzGibbon of Carleton University, Ottawa, Ontario.  A draft
of the thesis is available at http://www.cyberus.ca/~chris/webdoc7.htm


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/