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Environmental management systems- another fad, not a panacea

Environmental management systems can be viewed as management of those activities, products and services of an organization which have an impact on the environment. The ultimate aim of corporate environmental management must be to operate in a way which improves their environmental standards. However, the problem that many organizations face is: what constitutes an environmental standard? How do we measure our impact on the environment without bias?

The intrinsic complexity associated with environmental issues means it is difficult to understand all the feasible actions available to a firm for reducing its impact on the environment. Such complexity makes it hard to accurately assess the real environmental achievements accomplished by a firm.

Confronted by pressure from stakeholders such as the public, environmental groups, and government legislation, many firms have adopted environmental policies for compliance purposes. Such policies can be viewed as a general guideline that companies wish to aspire to. However, they provide little clarity as to how firms actually interact with the environment in their daily operations and are often cherry-picked to look favorably upon a firm’s activities.

Environmental management system standards such as the EU eco-management and audit scheme and the international standard ISO 14001 have been developed to provide organizations with a framework to implement an environmental management system in their activities. An environmental management system (EMS) consists of a number of interrelated elements that function together to achieve the objective of effectively and efficiently managing those activities, products, and services of an organization which have an impact on the environment.

A key element of ISO certification is to promote trust and accountability to stakeholders. This is typically achieved through an external audit, conducted by an independent, third party actor. However, despite the widespread prevalence of auditing systems, notable ‘gaps’ still exist between theory and practice, particularly regarding auditor impartiality. This can be partially attributed to the direct contracting and payment of ISO auditors by the organizations they audit. Rather than serving as a neutral third party figure, these auditors cater to a ‘customer-supplier’ type of relationship, mimicking that of a hired consultant. Such a relationship can contribute to an aura of rationality (rationality? is this the word you wanted to use here?) in which their information is obtained behind closed doors. Thus, while sustainability reports and audits are, in theory, conducted in order to disseminate information to stakeholders, such information may be skewed to favor corporate interests due to auditing biases.

The use of vague terminology within the EMS is another problem that is hard to ignore. There are a tremendous number of actors involved in environmental management schemes. Over 130,000 organizations around the world have been ISO certified. In this light, the scope of differing perceptions and definitions of environmental performance is vast, hence affecting the overall goals and actions of certified facilities. The measures taken to achieve established goals will depend on perceptions of the EMS and its role in a firm. Additionally, while facilities being certified for ISO 14001, for example, are required to establish environmental targets, the nature of the targets fails to be addressed. In essence, the effort put forth by individual firms will vary drastically depending on their interpretation of increased environmental performance. In this respect, even incremental changes are deemed perfectly permissible under ISO guidelines as long as a firm is making ‘headway’ on a goal.

Again, for many organizations, the implementation of an EMS is not primarily aimed at improving its legitimacy and internal practices, but it is often a symbolic action aimed at boosting external legitimacy.

Another drawback to EMS is the loose regulations regarding the integration of EMS, which may lead to decoupling between real organizations and the organizations prescribed by the EMS. Instead of adopting standards that actually lead to environmental sustainability, organizations tend to adapt the EMS to the standards that are already in place. Thus, there is a real danger that the daily activities are somewhat disconnected from the standards set by the EMS. Furthermore, voluntary agreements are a self-managed process. Therefore, its success depends largely on the management commitment present within an organization. Many organizations fail to achieve their sustainability goals due to lack of buy in from the management who might be unaware of the EMS program.

EMS does not establish performance standards and it doesn’t measure environmental performance. What it does is to assist organizations in reaching a target of increased performance. ISO 14001, for instance, is more concerned about processes than actual outcomes. Also, a company could, if it so wished, relocate to less restrictive nations and become an ISO 14001 certified company. It is also worth noting that companies aiming for ISO certification could set their own goals and targets. This could also be exploited by a company by setting easier goals which are achieved and subsequently stating to stakeholders their achievement of ISO 14001 certification, for instance.

Finally, the only element of ISO 14001 which is made public is the environmental policy statement. This lack of transparency is a major disadvantage of ISO 14001, since there is no requirement to make public any information about an organization’s environmental impact.

While acknowledging that self-standing instruments cannot be expected to achieve significant behavioral change, concerted effort should be made at various levels to enhance the effectiveness of Environmental Management Systems such as ISO 140001 and EMAS. The lack of clear guidelines or prescriptions and the overall ambiguity of the systems based on voluntary instruments are characterized by contextual conditions which dominate the process and where outcomes largely depend on which actors are active and most involved. How are the consumers with a lean towards sustainable products to be convinced to buy from certified firms with no real environmental outcome? These are some of the question we should ponder upon as we seek to improve the effectiveness and credibility of environmental management systems.