New Chapter Begins for ISO 14000 Series: From Revisions to Climate Change, Experts Have Much Work Ahead

Jason Hart
Editor, International Environmental Systems Update

STOCKHOLM—Standards writers from the International Organization for Standardization ("ISO") took advantage of several timely opportunities in June to advance the ISO 14000 series on environmental management systems to new levels during the eighth annual plenary for Technical Committee 207. Highlights from this Scandinavian wonderland included the official commencement of the revisions process for ISO 14001, greater awareness of the standards’ potential to reduce the effects of climate change and a fierce debate concerning participation from nongovernmental organizations ("NGOs") in the standards-writing process. Experts say it was one of the most historic and controversial sessions of the group to date.

Revision Gets Under Way
After nearly three years of intense negotiations on whether to revise ISO 14001, Subcommittee 1 members of TC 207 finally resolved to begin a limited revision of the environmental management systems standard. ISO member countries voted 36-0 to commence the process, with one abstention from the Netherlands. A tentative target date of 2003 has been set for publication. Standards writers were clear, however, about their message to the more than 17,000 companies that have registered to ISO 14001 and the thousands more in the various stages of implementation – no additional requirements will be considered in the new document. Any changes to the existing text of the standard will address two issues only:

1. Compatibility with the new ISO 9000 quality management systems series – slated for publication in November
2. Clarification of text within the standard to help users better understand its requirements through clearer language

Realizing the historic impact the meeting would have for the next decade and beyond on issues such as EMS implementation, certification credibility, environmental reporting and a host of other concerns, tensions were often high during the week-long session of SC 1. But in the end, most experts were pleased with the meeting’s results. "We made some really significant decisions this week," said Ossie Dodds, chairman of Subcommittee 1, who also was unanimously re-elected for another term as the group’s leader. "But the user community should be reassured. There are no big surprises coming over the horizon, and we are determined to try and make what I think is already a good standard even better. And that’s the whole purpose of this review and revision."

Dodds said that the issue of compatibility always has been a primary target to achieve for the subcommittee because it has been pressed hard by the user community as something that needed to be addressed, especially with the new ISO 9000 series hitting the streets at the end of the year. He noted that both TC 207 and TC 176 on ISO 9000 have been working closely together recently to ensure that compatibility issues are covered by both series of standards, and that quality management experts have included harmonizing text in ISO 9001:2000 that will deliver real value to the users. "They’ve already taken a lot of points on board in their deliberations," he said. "The objective is to try and make sure that future users and existing users can convert any changes in the standards without difficulty, without conflict and without confusion, so they can do their jobs easier, quicker and cheaper. It should also mean that we get more people using the standards, which means the benefits will spread even further."

Joe Cascio, chairman of the U.S. Technical Advisory Group to TC 207, agreed and said the revision process for ISO 14001 is now "right on target." He noted that the U.S. delegation would have preferred that ISO 14001 remain in a review stage to explore all revision options before taking action, but the subcommittee’s decision was a responsible one. "It sends the right message to the marketplace," Cascio said. "Organizations that are investing heavily in ISO 14000 will see stability in ISO 14001."

But as expected, not all delegates were pleased with the decision to revise ISO 14001 – at least not with its agreed-upon scope and schedule. Dick Hortensius of the Netherlands said that the Dutch delegation clearly was not supportive of the revision process commencing without further review, and that spending a lot of years on a "very narrowly defined revision" simply isn’t worth the time or resources it would likely cost. He also noted that although the 36-0 vote seemed one-sided in the end, it took the group several hours, continuous drafting meetings on language and three balloting sessions to reach the decision. "We would have liked to have seen an extended review period of ISO 14001 to identify significant issues that go beyond the current requirements and scope of ISO 14001," Hortensius said. "This sends the message back to the user community that ... they won’t be bothered with a new standard or new requirements for a number of years. I think those users will be satisfied by the decision. But there are many other stakeholders that have an interest in ISO 14001, and they will clearly be disappointed."

Hortensius explained that state-of-the-art developments in environmental management are evolving rapidly in the Netherlands as well as many other parts of the world, and new concepts – such as environmental reporting and product chain management – should be brought to the table for the subcommittee to consider. "Doing so will ultimately give continued market relevance and credibility of the ISO 14001 concept," he said. "We think that’s needed to really achieve sustainable development by applying ISO 14001." Many other SC 1 members agreed, and the group eventually established a formal process to monitor and document the issues that go beyond the current revision’s scope that likely will be raised as the revision moves forward. Those issues will be used as a starting point later this decade when standards writers begin another revision process in about 2006.

Once SC 1 reached its decision to revise, Working Group 1 began the process immediately by breaking up into three specific task groups to explore clarification in these areas:

1. Clause 4.3—Planning and related annex, chaired by Mexico
2. Clause 4.4—Implementation and related annex, chaired by the United Kingdom
3. The rest of the standard, including Clauses 1-3.0, 4.2, 4.6 and related annexes, chaired by Brazil

Dodds said the task groups were set up for those categories because users identified those areas as potential pitfalls when facing compatibility and interpretation of existing text during implementation of ISO 14001. He added that Working Group 1 will meet again in November in Brazil, where members will receive reports from the task groups on their progress in their respective areas, and standards writers can begin drafting text for the new document. "We’re still at the stage where we’re identifying possible solutions," Dodds explained. "But Brazil offers an opportunity to get into the actual drafting stage. Shortly after that, we’ll actually be looking at developing working documents and committee drafts through the formal approval process [that] ISO normally uses." But Dodds warned that the subcommittee still has a long process ahead, and estimated that three years to complete a new standard could be a "bit tight." He said the group could produce two committee drafts of a revised ISO 14001, which will add a few months into the process.

Hortensius said the Dutch delegation was still looking forward to making significant contributions to the revision process, and added that they would try to "stretch" the resolution taken by the subcommittee to take into account as many clarifications and improvements as possible within the current intent of the standard. For more information in the United States, contact U.S. SubTAG 1 Chairman Joel Charm at telephone (973) 895-5233.

Climate Change Task Force Strengthens Communication Efforts
TC 207’s Climate Change Task Force ("CCTF") also entered into new territory last month after initiating a slight transition with ISO’s newly created Ad Hoc Group ("AHG") on climate change. ISO’s Technical Management Board mandated the AHG’s formation in January to address a number of requests from ISO members and other stakeholders as to how the world’s premier standards body would tackle the growing climate change issue in a more strategic way. Operating from a proactive approach, TC 207 already had established the CCTF in 1998 to explore the role that the 23 standards in the ISO 14000 series might have to address the emissions reduction targets set by the Kyoto Protocol. Due to the work so far by the CCTF, negotiators from the United Nations Framework Convention on Climate Change ("UNFCCC") – the international body charged with developing and implementing the protocol’s requirements – have shown a growing interest not only in the standards themselves, but also in the consensus-building process used by TC 207 to create the standards for greater credibility. The CCTF and the AHG now will work together as often as possible to illustrate how ISO 14000 and other ISO standards can be used to facilitate the management, measurement and verification of greenhouse gas sources and sinks.

The CCTF met for two days here, ultimately redefining its scope to increase the group’s focus on the ISO 14000 standards and how they can contribute to the climate change debate, and redirecting a number of additional responsibilities to the new AHG. The group issued a revised 24-page report to explain the standards, how they potentially can improve a company’s environmental performance and how they can be applied to the Kyoto accord. The report will be used as a communication tool to get as many stakeholders involved and educated on the application of the ISO 14000 standards. Mark Barthel, chairman of both the AHG and the CCTF, said that although climate change is a "very sensitive issue" to some TC 207 delegations, the CCTF had an "incredible atmosphere of cooperation" to elevate the group’s work and communicate ISO 14000’s potential in the climate change arena. Barthel said 12 delegations and a group of nongovernmental organizations examined the revised report and provided constructive advice on how to improve the text. He added that the new report reflects the needs of the readership much more, and the document’s revised language isn’t so "ISO-centric" and can be used to negotiate with all the major players in the UN process.

Jim Connaughton, the U.S. delegate to the AHG, concurred, and added that the group now is gearing up to give presentations on ISO 14000 and the ISO infrastructure at a UNFCCC workshop slated for September in Lyons, France. Additionally, Connaughton said U.S. experts have been communicating with the Clinton administration’s task force on climate change to make sure U.S. negotiators are updated on ISO’s role with the UNFCCC. "We’re already a big step ahead of the game, in terms of supporting the Ad Hoc Group," he said. "All in all, it was a good meeting that stayed within the proper scope, which will put forward some good communication about our standards." For more information, contact Mr. Barthel by e-mail at mark_barthel@bsi.uk.

NGOs Fear ISO 14000 Process May Be Flawed
Although TC 207 experienced an unusual week with virtually no contention during the group’s dozens of sessions, ISO delegates ran their smooth-sailing ship aground during the closing plenary while attempting to address participation in the standards development process from nongovernmental organizations ("NGOs"). Experts had hoped to end the plenary’s last session in record time as the group cruised through most of the 30 resolutions developed by the more than 500 attendees during the week. But TC 207 reached a significant impasse on June 18 when discussing a final recommendation by a high-level task group commissioned by the committee to investigate the role that NGOs have played during the development of the ISO 14000 series. The closing plenary lasted into the early evening –

one of the longest ever – and ended without a solid solution to the NGO issue.

The group of experts, called the NGO Contact Group, which included involvement from three top officials in the United States, the Netherlands and Australia as well as a number of NGO representatives, recommended that its small informal assembly be raised to a new level – a formal TC 207 Task Group – to build on preliminary research gathered thus far. The group also recommended that the TC 207 chair, Dr. Margaret Kerr, invite the potential NGO Task Group to report or advise periodically on NGO issues to the Chairman’s Advisory Group ("CAG") – which facilitates all administration and leadership activities for the committee. Both moves would increase the awareness and voice of NGOs in the ISO 14000 development process significantly, experts say. But in its final report to the CAG and TC 207, the NGO Contact Group outlined its entire rationale for the proposal, stating that the appointment of the new task group and an NGO representative who could report to the CAG would send "a clear message" to the public interest community that the TC 207 leadership does indeed value NGO input.

That proposal clearly divided the technical committee during the final hours of negotiations, with some delegates warning that a sudden increase in power with one group could endanger the group’s coveted consensus-building process for standards development, while others stated that greater NGO participation could only strengthen the credibility of ISO 14000 to all stakeholders. After several hours of tense debate, TC 207 deferred the issue to be addressed through a four-month letter ballot to all member bodies to decide whether to form the NGO Task Group. If the results of the letter ballot are positive, the NGO Task Group will proceed and the NGO Contact Group will be considered disbanded. If the results of the letter ballot are negative, however, TC 207 will agree that the NGO Contact Group, with expanded membership from NGOs nominated by their member bodies and liaison organizations, will continue its work to further develop information on relevant issues. But most NGOs warned that if the ballot fails, many more would withdraw from the process despite proposed alternative measures to increase their participation.

The NGO debate is a major crossroads for TC 207 on a number of fronts, but the most important issues involve the potential use of the ISO 14000 standards to address public policy criteria in several countries – including the United States – as well as the role ISO 14000 could play to address the requirements of the Kyoto Protocol and reduce the effects of climate change. Since ISO 14000 began in the early 1990s, the series has been a different animal compared to other standards development processes and always has been surrounded by controversy simply because of what it intends to address – the environmental impact. Realizing this issue, TC 207 encouraged participation by all relevant stakeholders during every stage of development to ensure its consensus process had integrity. Some experts say that if ISO 14000 can pass the "sniff test" with public interest groups as a credible framework to improve environmental performance, which includes a development process with stakeholder integrity, then organizations that implement a robust system could benefit on a number of levels. Those benefits could include reduced trade barriers on a global scale, regulatory incentives for improved performance and reduced liability with financial institutions.

On the other hand, many participants in TC 207 are representatives from industry, who created the ISO 14000 series only to be internal management tools. Some believe the greater transparency that NGOs bring to the table could actually increase liability costs with potential future issues such as environmental reporting and other endeavors. In TC 207, an NGO is defined as a nonprofit association of citizens that operates independently of government or business structures and has noncommercial objectives related to environmental, consumer interest or sustainable development. Past NGO participants have included big names such as Friends of the Earth, the Sierra Club and the National Wildlife Federation, to name a few. But a number of those major players dropped out after relatively short periods of activity. To address this, the NGO Contact Group was developed in 1998 in San Francisco to examine why NGO involvement within TC 207 had fallen significantly since about 1996. When queried about the dropout rate, the majority of NGO participants cited a lack of funding and a limited ability to affect the standards development process. To that end, the Contact Group spent two years developing its recommendation, which included meetings with dozens of NGOs in several countries, as well as two final sessions here June 13 and 17. And of the more than 500 participants in TC 207’s plenary this year, only a handful were NGOs.

Additionally, to make matters worse, NGOs received another blow last month with the resignation of WWF International – a major environmental interest group – from the entire TC 207 process. WWF had been actively involved with ISO 14000 since 1994, but stated in a June 7 letter to the TC 207 leadership that the work had drained significant resources, and the absence of an external funding mechanism for ensuring NGO participation in the process and a general "lack of support" forced them to resign its liaison status. But the letter also pointed out that the support issue affects not only NGOs involved with ISO, but also European NGOs engaged in similar standards activities in the European Union. These developments had some experts concerned about the future credibility of TC 207. "I honestly believe that we should work very closely with the NGOs and with others, and I’m hoping that the ballot is going to be positive so we can work together more closely," said Ahmed Husseini, TC 207’s international secretary. "I think TC 207 is a pioneer in this area, and I’m sure all the members of TC 207 mean well and will work hard in their national groups to come up with a solution to NGO participation."

Husseini, who has followed the NGO issue closely for years, states he believes the plan proposed by the NGO Contact Group is "very reasonable" and that the group should move ahead quickly in this area. But he added that the ballot and decision to create the group is completely up to the members, and he will respect any decision taken. Joe Cascio, chairman of the U.S. Technical Advisory Group, said that although the NGO issue is very complicated, it’s also very easy to solve. But he stressed that the committee should be careful about giving special treatment to any group involved in the process. "The fact of the matter is, this is a committee that’s devoted to environmental issues, so everyone in effect, is working for the betterment of the environment," Cascio said. "Frankly, there are no special views. All views are special. It’s true that there are differences of opinion, but those differences are ones that make the discussions and ultimately, the consensus that we reach."

Cascio explained that if TC 207 begins to treat NGOs in a differential way, the whole process could be opened up to other groups as well, including special industry groups, different countries with population and resource issues and a host of others. He said that is the root of the controversy with the NGO Contact Group recommendation – not increased NGO participation. After so much debate on the issue, NGOs were obviously disappointed about the controversy their enhanced participation in the process caused. But all were still optimistic on the future when the ballot closes in September. Jason Morrison of the Pacific Institute said he welcomed the formal letter ballot as an opportunity for NGOs because the results would provide the clearest indication to date as to whether TC 207 is "sincere" in its stated interest to find meaningful mechanisms for enhancing NGO involvement. "NGOs have been told for years now that our input into the standards development process is valued and that there is an interest in improving our currently limited involvement," Morrison said in a statement. "If the proposal is voted down, it will illustrate that the years of verbiage regarding the desire for more meaningful NGO participation has in fact been disingenuous. This vote represents an important crossroad for TC 207." Morrison added that the ballot’s results would send one of two messages to NGOs: Either that progress can be made by working within the system, or that progress cannot be made and that NGOs should consider redirecting their efforts and resources elsewhere.

Ken Ogilvie of Canada’s Pollution Probe said in a statement that TC 207 members "should appreciate the delicate position" of both TC 207 itself and the NGOs who are trying to build a cooperative and productive relationship. A negative vote on the ballot, he warned, could effectively end the involvement of many of the NGOs who are currently participating in TC 207. "The likelihood of ever again attracting significant NGO involvement in TC 207 would be very small," Ogilvie said. "NGO involvement is already below ‘critical mass’ to ensure that the public and policymakers will easily accept the ISO 14000 standards as a valid input to public policy related to sustainable development. The possibility of a widespread NGO backlash exists and should be avoided at all costs." All NGOs said they would be lobbying hard during the next four months to persuade TC 207 members about how important their votes will be for the credibility of ISO 14000 in the future.

Editor’s Note: Jason Hart is editor and publisher of International Environmental Systems Update, the world’s leading publication on ISO 14000 and the environment, published by CEEM Inc. Mr. Hart may be contacted by telephone at (703) 250-5900, or by e-mail at jason.hart@ceem.com. For more information on the proposed NGO Task Group, contact Jason Morrison by telephone (510) 251-1600, or by e-mail at jmorrison@pacinst.org.