Tackling the Big ISO 14001
Task: Identifying Environmental Aspects


by Gregory J. Hale and Caroline G. Hemenway

The key to a successful registration
is to figure out which
impacts are significant and deserve the most
attention.

You've made the decision. You have senior-level commitment and a budget to begin implementing the ISO 14001 environmental management system specification standard. The gap analysis is completed, and the implementation team is assembled. You have representation from all parts of the organization, including quality, environmental, financial, manufacturing, marketing, sales and human resources.

The time has come for you-the ISO 14000 champion-to pull this group together and begin identifying the environmental aspects and impacts of your organization. Experts agree that this exercise is the lifeblood of successful implementation and continuous improvement of your environmental management system. At this point, you may be asking, "We have to file a Toxic Release Inventory report for the EPA and a lot of other information; what more do we need to identify?"

ISO 14001 defines an environmental aspect as any "element of an organization's activities, products and services that can interact with the environment." You can see the document implicitly asks you to go beyond what government regulations may require and leaves the hard work up to you. The key to successful registration is to figure out which impacts are significant and deserve the most attention, and which impacts are secondary and can wait for another day.

Depending on the source of your information, you can use several techniques to identify significant environmental aspects and impacts. Some experts advocate the straightforward, regulatory approach, meaning you peruse your organization's permits and legal responsibilities, drawing on them for a list. Others advocate a life-cycle approach, which involves a detailed, quantifiable breakdown of each part of the process. The latter resembles the techniques used by financial auditors.

Cause and effect
A cause-and-effect relationship exists between environmental aspects and impacts. An environmental aspect refers to an element of an organization's activity, product or service that can have a beneficial or adverse impact on the environment, according to ISO 14004, the EMS guidance standard in the series. Examples of aspects include discharges, emissions, noise and consumption or reuse of materials. An environmental impact refers to the change that takes place in the environment as a result of the aspect. Examples of impacts include contamination of water or the depletion of natural resources.

ISO 14004 suggests that organizations can identify environmental aspects and evaluate their impacts in four steps:
Select an activity or process.
Identify environmental aspects of your company's activity, product or service.
Identify environmental impacts.
Evaluate significance of impacts.


Because the significance of environmental impacts can differ for each organization, most experts agree that quantification can aid in the evaluation process. ISO 14004 urges organizations to consider environmental and business concerns when identifying and evaluating environmental aspects. For example, the document suggests examining the scale, severity, probability and duration of the impact. Business concerns include: potential regulatory and legal exposure, difficulty in changing the impact, cost of changing the impact, effect of change on other activities and processes, concerns of the parties involved and the effect on the organization's public image.

Relating quality of materials to aspects
Several experts acknowledge the close relationship between the quality of materials used in manufacturing processes and their associated environmental aspects.

If you know the specifications of the materials required to produce high-quality products and are managing your supplier carefully to meet those requirements, then you have an effective means for understanding the environmental aspects of your materials, says Robert Ferrone, president of Ferrone Group, an engineering consulting firm specializing in ISO 9000 and ISO 14001 implementation.

"By improving your understanding of the environmental aspects of specific chemical or hazardous substances contained in your incoming materials, you are in a position to work with your supplier to improve the environmental quality of your products and manufacturing processes," explains Ferrone.

Another example of the relationship between quality and environmental aspects is the correlation between quality defects and environmental aspects. "An environmental aspect of your process, such as the use of an industrial solvent for cleaning parts used in products, may, on closer inspection, indicate a quality process deficiency in parts production that requires a cleaning step," he adds. "Solving the quality problem may also remove the environmental aspect."

Regulated vs. unregulated aspects
Environmental aspects can be classified under two broad categories, according to C. Foster Knight, managing director of Knight & Associates and former corporate environmental counsel to Digital Electronics Corp. The first covers all environmental aspects regulated by applicable laws and regulations. The second involves unregulated aspects that companies should consider when developing their management system.

"An environmental aspect signifies the potential for an environmental impact," explains Ferrone. "A specific activity, product or service may already be tightly controlled to prevent environmental impacts. The fact that it has the potential for environmental impacts makes it an environmental aspect within the meaning of ISO 14001.

"It does not matter whether the activity, product or service is regulated to protect the environment. What matters is only whether there is a potential for an environmental impact under reasonably foreseeable conditions, including absence of voluntary or regulated environmental controls, legal environmental releases of air emissions and wastewater effluents (i.e., below regulated limits), accidents, breakdowns of environmental pollution controls, misuse of products by consumers or improper end-of-life product disposal by customers."

Knight says most industrial facilities already document how environmental, health and safety regulatory requirements apply to their operations. Typical manufacturing plants may use checklists or compliance self-assessment tools for protocols to determine if they're in compliance. Various water-pollution-control regulatory requirements may apply to the plant's operations, including general pretreatment standards and possibly specific pretreatment standards for specific toxic wastewater constituents.

Knight suggests developing a comprehensive set of material-safety data sheets for all hazardous substances. These MSDSs will go a long way toward collecting the necessary information to establish environmental objectives and manage environmental aspects.

Environmental aspects
of products and services
Most U.S. industrial facilities already have some kind of documentation system for identifying and managing compliance with EHS regulatory requirements applicable to their activities and operations, says Knight. For example, manufacturers must contend with air emissions, waste-water effluents and other hazardous wastes. However, manufacturers face a bigger challenge when it comes to identifying regulated aspects associated with the facility's products and services.

Environmental product-related regulatory requirements are a useful source for identifying certain environmental aspects because many developed countries must deal with such requirements to participate in various trade markets within the European Union. Multinational companies with engineering, manufacturing, product line and marketing groups in different countries track this information within each department but usually don't assign this task to an EHS manager. However, smaller companies often assign the task of tracking environmental product regulations to a senior EHS professional, according to Knight.

"Engineering, product line and marketing groups may have established systems for monitoring environmental product-related regulatory initiatives to ensure that affected products can be sold legally," says Knight. "In the case of environmental laws governing toxic substances in products, such as the Toxic Substances Control Act and similar laws in Canada, Europe and some Asia-Pacific countries, you can usually find the expertise for managing compliance within the manufacturing plant.

"Product-related toxic substances control laws require manufacturers to have systems in place for identifying 'new chemical substances' [those not already on a list of substances approved for use in commerce], for reporting 'new chemical substances' to regulatory agencies, for testing and for making other kinds of reports."

Existing systems and documentation used for identifying activities and products may not prove too useful when it comes to identifying environmental aspects of services, admits Knight. However, the basic information can be developed by understanding the specific "services" your facility offers.

"For example, if the facility provides product maintenance and repair services, you likely will find that chemicals and hazardous materials are used when you provide the service," says Knight. "Again, you can use your MSDSs as a tool for identifying environmental aspects."

Unregulated environmental aspects
Besides tracking regulated environmental aspects, another useful source for identifying environmental aspects is seeking out those aspects that are regulated up to a specific point and those that are not regulated at all, says Ferrone. Recurring examples of unregulated environmental aspects affecting most industrial operations are:
Water and energy consumption.
CO2 releases.
Unregulated (or minimally regulated) wastes such as many forms of nonhazardous solid waste.
The still largely unregulated aspects of transportation.
Many types of end-of-life product disposal.


ISO 14001 specifically limits the scope of the environmental aspects identification process to environmental aspects that a facility or site "can control and over which it can be expected to have an influence." This requires a practically oriented systems approach that allows for continual improvement over time, notes Ferrone. Because many environmental aspects identified through this systems approach involve waste, the environmental aspects identification process can lead to very significant opportunities to improve resource productivity.

"Practical approaches can be as simple as making an inventory of unused or unusable materials and solid wastes at the facility or site, then examining the opportunity costs of unused and waste materials to rank their significance," adds Ferrone.

SSI Technologies experience
Douglas Wall, corporate environmental manager of SSI Technologies, a medium-sized auto parts company in Janesville, Wisconsin, gathered all the company employees together and conducted a brainstorming exercise to identify environmental aspects. The multifunctional teams identified five general categories of environmental aspects that related most to their activities, products and services:
Operations processes
Raw materials and transportation
Process waste recycling
Packaging
Disposal

The team classified each aspect and used a simple rating system to grade them.

SGS-Thomson Microelectronics experience
In January, SGS-Thomson Microelectronics Inc. in San Diego became the first facility in the United States to achieve certification to the draft international standard version of ISO 14001. The SGS corporate office mandated that every facility worldwide implement and have a third-party auditor verify conformance to the European Union's Eco-Management and Audit Scheme regulation by 1997. Having ISO 14001 was just "icing on the cake," according to SGS personnel. As part of the implementation process, the facility's senior managers developed a comprehensive method for identifying the environmental aspects related to the operation and, as did SSI Technologies, ranked the aspects according to gravity and severity.

The key to any environmental management system is the mechanism employed for identifying aspects and impacts associated with a company's processes, products and services, according to Patrick Hoy, the site environmental manager. To prepare for the EMAS formal assessment, the Rancho Bernardo facility followed the failure-mode-and-effect analysis corporate standard developed for assessing the potential significance of each environmental effect identified.

"As part of the corporate standard, our team conducted a review of all regulations that applied to the facility, any pending environmental legislation, corporate requirements and all media-specific permitting conditions," explains Hoy.

Hoy ranked each impact according to its significance and where it stood on the corporate list of overall environmental effects. He notes that the facility compiles a register of potential environmental impacts and makes it available to the public through its annual environmental statement. During the assessment, conducted in early 1995, the company identified two potentially significant impacts that, left unattended, could have caused significant negative impact to the environment surrounding the facility.


Operations approach
Christopher Bell, a partner in the legal firm Sidley & Austin and a key U.S. negotiator in the standards-development process, lists some other ways companies can identify environmental aspects. For example, you can begin from the operations side of the business by first identifying the organization's key activities such as major manufacturing operations. Then, by associating specific environmental aspects with those activities (emissions into the air of specific constituents), you can begin to identify the type of impact related to that aspect, such as carcinogenic air emissions.

Another approach might be to start from the state-of-the-environment perspective by identifying key contributors to the global warming phenomenon, such as water quality or ambient air quality.

Another method involves working from existing data on discharge and emissions, and then organizing those data in terms of both quantity of discharges and emissions, and the toxicity of those emissions. This provides companies with a quick way to prioritize aspects, notes Bell.

Companies may also begin from a resources perspective and focus on the raw materials and natural resources used by the organization and the environmental consequences associated with those uses, he adds. This method also may include what is known as a "mass-balance" analysis, where the inputs to the organization's systems are balanced against the outputs to develop a detailed view of the environmental issues associated with the organization.

About the authors

Caroline G. Hemenway is publisher of CEEM Information Services in Fairfax, Virginia. Gregory J. Hale is associate editor of International Environmental Systems Update, a monthly newsletter on ISO 14000 developments and implications. CEEM publishes IESU and several other ISO 14000 and management systems products. For more information, contact CEEM at (800) 745-5565 or (703) 250-5900; fax (703) 250-4117.