ISO 14001 Reconsidered

Reader Desmond B. writes:

“Browsing through your site, I was interested by your relatively neutral presentation of the ISO programme. You presented some interesting aspects of the bureaucratic inanities, as well as some of the difficulties of applying euro-centric standards (the symbology not being applicable worldwide) on a global scale. It seems as though there are many positive aspects to the ISO programme (your mention of Toyota’s practices), it appears that there is relatively little citizen/democratic control or oversight of this organisation. It’s one thing to standardise container sizes, but environmental management procedures should perhaps be a more public affair. Curious to see some critical comment from you regarding this, especially considering the frequent mentions of ISO on your site.”

True enough. In my two posts that mention the ISO I was fairly neutral. I was less concerned about democratic accountability of the ISO because the standard setting process is fairly open and decentralized, and standards compliance is entirely voluntary. It is up to governments, not the ISO, to legislate, regulate, or enforce implementation of the standards.

Standards are developed by consensus of broad-based technical committees and working groups. According to the ISO site:

“In these committees, qualified representatives of industry, research institutes, government authorities, consumer bodies, and international organizations from all over the world come together as equal partners in the resolution of global standardization problems.”

Though the views of these interests are taken into account in the standard development process, only ISO “member bodies” can actually participate in the final vote. A member body of ISO is the national body ‘most representative of standardization in its country’. Only one such body is accepted from each country.

That said, the ISO’s consensus process is becoming less open:

“As part of the streamlining of existing procedures, ISO committees will in future, subject to certain conditions, have the option of dispensing with the committee stage — the part of the ISO process during which national positions are debated in order to reach consensus within an ISO committee — and with the final approval stage, during which the texts of final standards are submitted for formal approval by the full ISO membership.” [source]

The ISO’s patent policy highlights the need for more public participation, accountability, and oversight.

The ISO requires individual or corporation’s holding patent rights on any part of an ISO standard to grant usage rights freely or under “reasonable and non-discriminatory terms and conditions” that apply throughout the world. While this may seem fair, the working committee of the relevant standard determines what is “reasonable and non-discriminatory.” This policy has kept some technical standards out of the public domain and from being implemented in some Free Software projects. For instance, it is impossible to write Free Software which can encode or decode MPEG-2 video or encode or decode MPEG-1 Layer 3 audio in the United States. When the organzation that sets standards for the Internet, the W3C, floated its own draft policy considering “reasonable and non-discriminatory” licensing fees, it was widely condemned in public comment and eventually dropped in favor of a draft with royalty-free licenses.

As Desmond notes, though, environmental management procedures are a different matter from, say, standard paper sizes.

The major requirements of an Environmental Management System (EMS) under ISO 14001 include:

• Issuing a policy statement which includes commitments to prevention of pollution, continual improvement of the EMS leading to improvements in overall environmental performance, and compliance with all applicable statutory and regulatory requirements.
• Identification of all aspects of the community organization’s activities, products, and services that could have a significant impact on the environment, including those that are not regulated
• Setting performance objectives and targets for the management system which link back to the three commitments established in the community or organization’s policy (i.e. prevention of pollution, continual improvement, and compliance)
• Implementing the EMS to meet these objectives. This includes activities like training of employees, establishing work instructions and practices, and establishing the actual metrics by which the objectives and targets will be measured.
• Establishing a program to periodically audit the operation of the EMS
• Checking and taking corrective and preventive actions when deviations from the EMS occur, including periodically evaluating the organization’s compliance with applicable regulatory requirements.
• Undertaking periodic reviews of the EMS by top management to ensure its continuing performance and making adjustments to it, as necessary. [source]

The ISO 14001 is a process for environmental management that may be applied to just about anything. It is not an environmental performance certification. The ISO itself notes:

“ISO 14001 does not establish performance requirements or specific criteria and indicators for defining sustainable forestry. Among the misleading practices that ISO wants to put an end to [is]... giving the false impression that... ISO 14000 is a label signifying a ‘green’ or ‘environmentally friendly’ product. This is not so. They are not product standards.” [source]

Nor does the auditing process include public oversight.

“Companies write their own public environmental policies — compliance with these policies, or even compliance with the law, is not a condition of certification. ISO 14001 certifications neither audit nor verify on-the-ground environmental performance. Public consultation is not a requirement of the certification process, nor are public summaries of certification audits required. Because ISO 14001 has no forestry performance standards, any forestry company — from the most environmentally destructive to the most well-managed — can be certified. Contrary to claims by the Canadian Pulp and Paper Association, third party audits to the ISO 14001 standard do not ‘ensure sustainable forestry’.” [source]

Indeed, Greenpeace criticizes the ISO 14001 standard and its use by the Vancouver-based company International Forest Products (Interfor) to “greenwash” its logging operations in old growth rainforests along the coast of British Columbia.

“Weaknesses of the ISO 14001 standard include:

• Compliance with the environmental policy, or even compliance with the law, is not a requirement of certification — the company sets the environmental policy
• ISO 14001 neither sets nor endorses any environmental performance standards, in forestry or in any other industrial sector
• ISO 14001 certifications neither audit nor verify on-the-ground environmental performance
• Public consultation is not a requirement of the certification process, nor are public summaries of certification audits required
• ISO 14001 is not an environmental labeling system
• ISO has no effective controls to prevent misleading marketing claims related to ISO 14001 certifications.

Environmental management system (EMS) certification schemes are completely different from environmental labeling schemes. As the ISO points out, “Two organizations carrying out similar activities but having different environmental performance may both comply with its [EMS] requirements.”

Environmental labeling, on the other hand, requires performance above a threshold. The environmental label is only awarded if a product or service has reached this level. The distinction between ISO 14001 and environmental labeling is essential. Because ISO 14001 has no forestry performance standards, any forestry company — from the most environmentally destructive to the most sustainable — can be certified. An ISO 14001 certification tells the consumer nothing about the relative environmental performance of any company’s, including Interfor’s, forestry operations.” [source] (Emphasis added.)