ISO 14000 has come into its own since its inception in 1996, and European Union countries are at the forefront of those being registered. Fueled by ISO 9000's success and an enhanced eco-awareness by the worldwide community, ISO 14000 achieved worldwide recognition in a remarkably short period. The reaction from EU companies has been particularly astounding, with more than half of the nearly 6,700 ISO 14001 registrations worldwide coming from EU countries. The United Kingdom leads EU countries with about 1,000 ISO 14001 registered sites; Germany is next with about 950 (see Figure 1). Japan is the only country to surpass these two, with more than 1,200 sites registered.

When looking at the numbers of registered sites in the European Union, it is important to remember the size of each country. Some countries have tried to prove they are at the "top of the list" of registrations by comparing the number of registrations to gross domestic product, to population size or to export quantities. As usual, statistics can be used inappropriately.

To understand the current state of ISO 14001 in the European Union, it is first important to understand the overall EU legal framework and its dealings with environmental issues. The European Union is comprised of 15 nation-states, each of which is subject to the overall legislation requirements of the EU Parliament. However, many states have their own national law that goes further than the "umbrella" EU law; some of these national legal codes vary in character.

The main drivers for most new EU environmental law come from those nation-states that are most active in environmental issues (e.g., Denmark, Germany) and the Environmental Directorate DG XI (the EU civil service department covering environmental issues). The civil servants within DG XI have been actively promoting EU environmental programs and legislation for many years.

EU environmental programs existed prior to the release of ISO 14001. One program requires companies to integrate environmental "thinking" into all business decisions. As a result of this requirement, the EU civil service has been active in promoting new environmental programs; two of these -- eco-labeling, and the Eco-Management and Audit Regulation (EMAR) -- are important to consider when looking at the current status of ISO 14001 in Europe.

Eco-labeling and EMAR

Environmental Awareness Within the European Union Some European countries have a long history of environmental interest among the general public (e.g., Denmark). This public awareness manifests itself at the political level, causing national environmental legal change within the EU Parliament. Thus, the countries with the most active public pressures are the ones that are influencing EU environmental policy making. Ultimately, EU environmental law is drafted by the civil servants within the EU Commission. The EU Commission is comprised of several Directorate General departments -- DG XI deals with environmental issues within the European Union. The EU Parliament meets periodically in Strasbourg and ratifies the legislation created by the EU Commission.

Eco-labeling predates ISO environmental labeling guidelines. It aims to achieve the same results as the third-party product labeling approval programs developed by ISO/TC 207, the technical committee responsible for drafting ISO 14000. This eco-labeling program may positively influence some companies' decision to implement ISO 14001 because it forces them to evaluate their products' overall environmental impacts. This evaluation forms a logical entry point into the aspects and impacts assessment that ISO 14001 demands. However, there are no figures available that correlate eco-labeling scheme applications with ISO 14001 registrations.

As with eco-labeling, many similarities also exist between EMAR and ISO 14001 registration. Yet, unlike ISO 14001, EMAR is a piece of European law.

A voluntary registration program does exist that enables organizations within the European Union to verify that their environmental management system meets a set of criteria outlined in the Eco-Management and Audit Scheme document (EMAS is contained within EMAR). The European Union created EMAS to promote improved environmental performance among EU companies. It is a voluntary regulation. Therefore, whereas all EU countries must adopt EMAR and have the internal framework (registration systems) in place to support it, it is not mandatory for any company to register to EMAS (the criteria). EMAS registration is only applicable and available to certain types of industrial sites within the European Union because it is part of an EU regulation (EMAR).

Recently, the European Committee for Standardization (CEN) agreed that compliance with ISO 14001 requirements satisfies most EMAS requirements. In addition, organizations need to:

 Develop an environmental performance statement for the site (the EMAS documents contain a list of the requirements for this statement)

 Communicate to customers on the environmental issues of the products or services that are supplied, including potential disposal problems

EMAS currently is undergoing revision (proposed release date is early 1999) to more closely align with ISO 14001. However, organizations probably will still have to meet some additional requirements above the basic ISO 14001 specification, and certainly the concept of the environmental performance statement will remain.

EMAS can influence European companies, causing them to consider whether to implement ISO 14001. An organization can choose to go directly for EMAS -- in which case it can "pick up" ISO 14001 as a kind of bonus on the way -- or it can register to ISO 14001 as an interim step to abide by EMAS requirements.

Why implement ISO 14001?

Numbers Don't Tell the Whole Truth Actual numbers of registrations do not always indicate ISO 14001 activity. At the TC 207 conference in San Francisco in June, Mary McKeil, vice chairwoman of the U.S. TAG groups, reminded everyone that while there appears to be plenty of interest in ISO 14001 in the United States, not many U.S. organizations are presently demanding registration.

EU companies implement ISO 14001 for the same reasons companies in other areas of the world do, including:

 To meet a perceived market need (and circumvent a potential trade barrier)

 To enable the organization to more easily satisfy regulator requirements

 To meet perceived pressures from interest groups, such as the local community and financial organizations

Within Europe, companies use ISO 14001 as a method to demonstrate their environmental credentials. Plus, European companies confront three additional issues:

 Perceived social needs. This is especially true in Denmark (also in Japan, where "social responsibility" is cited as the main reason for implementing ISO 14001)

 Stockholder pressures. Increasingly, organizations are under pressure to demonstrate to their stockholders (or potential investors, unit trust managers, etc.) that they are environmentally "sound."

 EMAS requirements (as stated above)

So far, EU companies have not experienced the supply-chain pressures that fueled the phenomenal growth in ISO 9000 registrations. This probably has much to do with the more diffuse stakeholders for ISO 14001. However, pressure continues to mount as companies "encourage" their suppliers to seek ISO 14001 registration.

Implementation problems

Compared with the early days of the series, organizations are experiencing fewer implementation issues and problems. However, organizations that wish to obtain ISO 14001 registration still encounter a number of difficulties:

 The lack of good, professional advice and qualified consultants.

 The lack of good, professional auditors. Many registration auditors come from a quality background and remain entrenched in the "full documentation" concepts that ISO 14001 has thankfully avoided.

 The high level of variability in the quality of the registration process.

 The high cost of registration. Although "high" is a relative term, if companies want professional auditors that do a good job, then they must be willing to pay for that premium.

 Limited understanding of what constitutes a reasonable attempt at an environmental aspects assessment. Confusion also arises over what actually constitutes an environmental aspect.

 Limited understanding of the tolerance allowed in responding to many ISO 14001 clauses.

 Employees' ignorance of basic environmental issues.

Assessing integration issues is an even more difficult problem. In general, integrated systems consist of existing systems with new processes incorporated into them (e.g., documentation control systems, training systems, communication systems). The control of these systems varies, and, depending on the organization, the role of the environmental representative can be handled by a variety of individuals -- from the health and safety expert to the technical environmental legal expert.

Again, these difficulties are not unique to the European Union; they can occur in any country, with the lack of professional advice especially prevalent in developing countries.

Size is an issue

In the European Union, many organizations are classified as small and medium-sized enterprises (SME). In general, a company of less than 50 employees qualifies as an SME, although in some countries this figure rises to 150. Most of the European Union is experiencing a very slow uptake by SMEs of ISO 14001, with very few registered SME sites.

In Denmark, on the other hand, SMEs represent 80 percent of the registered sites. The reason: Denmark has made a national commitment to help SMEs with their obligations to legal and other requirements. Due to this support, the Danish SMEs that have gained ISO 14001 registration have experienced a growth rate of more than 10 times the national average, according to a report by Tage V. Anderson of Denmark at the June 1998 international TC 207 meeting. This statistic echoes the results of a Canadian study which concluded that when organizations consider ISO 14001 implementation costs, the initial high expense of registration is outweighed by the long-term benefits for SMEs.

When it comes to implementation, however, studies in Denmark, the United Kingdom and other countries have shown that the problems experienced by SMEs are no different from those experienced by larger organizations.

A current issue in ISO 14001 registrations in Europe involves companies known as micro-businesses -- those with less than 10 employees. Such organizations have less formal procedures, wider employee knowledge of system operation, multiskilled and multifunction employees, and quicker response when fixing a problem.

Generally, ISO 14001 as written applies to any size organization. However, problems can occur when a registrar demands formalized procedures that are more applicable to large organizations. This view implies that registration can only take place with well-defined systems, in traditional documented terms. So the real problem seems to lie with how to assess a micro-business -- a hot topic among members of the registration industry. A consistent set of auditing rules for this type of organization has not yet been formulated.

Who is registering?

In the first wave of European registrations, many companies applying for ISO 14001 already were registered to ISO 9001 or ISO 9002. This picture now seems to be changing. Up to 30 percent of organizations (much higher in Germany) are now going directly to ISO 14001 without first registering to ISO 9001 or ISO 9002. This indicates that ISO 14001 has captured a new area of interest and participation apart from traditional quality management registrations.

A much wider variety of organizations are interested in ISO 14001 and EMAS in the European Union than are interested in ISO 9000. For example, several local governments in the European Union have already achieved EMAS registration, and many more are following suit. This trend has encouraged other national organizations -- such as military units -- to pay attention to ISO 14001 or EMAS. In Japan, many local authorities have been granted ISO 14001 registration, and the Japanese environmental protection agency has declared its intention to seek registration to ISO 14001 in the near future.

ISO 14001 and environmental performance

Environmental performance within ISO 14001 was discussed at length during the TC 207 SC1/WG1 drafting phase, with notably differing views between the United States and Europe. Since then, neither view has changed considerably -- Europeans prefer to add an auditable environmental performance improvement element within ISO 14001; the United States prefers not to add this element, focusing instead on defining a comprehensive EMS. The standard currently defines continual improvement as improvement of the EMS, which should result in performance improvement. The United States is satisfied with that approach. Japan, however, shares the European opinion, and as the world leader in ISO 14001 registrations, it carries considerable clout.

This might create some problems in the future because organizations could include an extra element of environmental improvement within an EMS and have a registrar audit it. Yet if this happens, and if an EMAS with a performance improvement element rises in popularity, then ISO 14001 could be seen as a "lesser" certificate.

These are some of the questions and problems relating to ISO 14001 in its early stages. Organizations and registrars should not be dismayed, but rather consider with open minds these issues as they emerge. The European Union is ahead of the United States in registration numbers and experience, but not necessarily in the larger area of legislation compliance. This is not a competition, and should not be seen as such. By working together, we will all benefit from new insights into the complex world of environmental quality management.

About the author

Nick Lister is a senior consultant with Excel Partnership in the UK. He has assisted organizations on EMS and environmental assessment techniques for more than 20 years. He trained the first group of EMS certification body auditors, as well as accreditation body auditors in several countries. In 1993, he piloted the world's first EARA-registered EMS Auditor training course.

For more information, e-mail Lister at nlister@qualitydigest.com .