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A Guide to Driving Environmental Performance

12 December 2016
This article focuses on three organizational levels to uncover the role and function that each play, and take a look at the concept of environmental performance evaluation (EPE) under the supporting standard ISO 14031.

Planning is a process of reaching logical decisions based upon reliable evidence. Many organizations will hold environmental aspect/impact registers, risk registers, and environmental audit reports as documented evidence of their environmental risk. It goes without saying that environmental performance objectives are often required to reduce, contain or eliminate environmental risks which could otherwise lead to circumstances of environmental harm and legal non-compliance.

In addition, planning is a process of setting strategic objectives that enable continual improvement. This means that the potential of an organization to improve its environmental performance can go far beyond risk, to include the aspirations, goals and opportunities that improve its environmental management, enhance the environment and connect employees to the big issues facing society today.     

Once you have sufficient information with which to plan changes, you then need to establish the environmental objectives of your organization. This could mean using the SMART model.

S = specific. If you were to look to reduce your waste, for example, then you would need to decide whether this means to eliminate it altogether (e.g. paperless working), to recycle it, or to reprocess your waste (e.g. bio digester). You should also consider which waste streams you should prioritise or even to discount from your objectives. For example, many manufacturers’ will prioritise their hazardous waste objectives where they pose a greater environmental risk.

There are instances where organizations also need to demonstrate a holistic perspective when they decide waste objectives. For example, organizations need to recognise their discharge of waste into public sewers in order to demonstrate that they have considered the full extent of their waste.

M = measureable. Working again with waste as an example, you can usually measure the tonnage of waste produced over as set period of time. Alternatively, many organizations choose to adopt objectives that are divided by variable factors:  examples include the number of operatives or employees, bulk production, gross productivity, or simply the number of orders completed. The latter would give you: 
Waste tonnage ÷ number of orders completed ÷ time; thus allowing you to glimpse your organizations real-time performance - perhaps over several sites.

Much of the new environmental sensing technology, such as chemical sampling metres, will only take measurements at set points across your operations, and it is accordingly advantageous to consider whether you sampling is fast enough to capture the rate of discharge. It is also vital to understand the need of measurement frequency, accuracy, and calibration.     

A = attainable. Are these objectives feasible to your organization? The challenge here lies not so much with planning and delivering the correct resources to enable change, which is nevertheless an important consideration, instead it should be to look at the more emergent difficulties that the organization might encounter.

Language barriers, for example can lead people to incorrectly segregate waste; poor and deteriorating relationships with neighbours can lead to increased numbers of complaints; and bulk returns can generate waste and sometimes even pollution if the storage of certain materials and chemicals is not controlled. It helps to draw up a risk and contingency plan. 

R = realistic. Sometimes it is better to fail at trying to do something well. Assessors look for improvements in how you have attempted to reduce your environmental impact. This means that if you have installed electricity metres, LED lights, sensors, timers, and low energy technology, but you have failed to smash you 50% energy reduction target – that is fine.

Don’t worry. ISO 14001 functions to identify points where you management system could be improved (which is considerably more valuable than simply verifying a company’s performance). Providing that an organization has correctly implemented the other requirements of the standard, such as an internal audit and management review, there are legitimate occasions when environmental performance is not representative evidence of continual improvement. Such as if you had a lull in production. 

T = time-bound. Focus on whether your objectives can be achieved within the goal of completion. People will often need some time to adapt. However, for plans like new green technology, waste compactors, biomass burners and energy efficiency improvements, you should set a defined completion date. Project and programme management is often used to implement SMART objectives; one example that springs to mind is a waterfall project plan.  

Operational Control

The second factor in your organization’s success is to determine how you will control your operations to achieve environmental performance objectives. This means that you need to establish your activities and their associated environmental aspects (such as the relationship between combustion and toxic air pollution), and that you need to design operational controls based upon these risks.

The control for combustion processes for example, is usually a combination of regular maintenance, carefully controlled and supervised operations, and emissions (stack) monitoring. It is also important to understand the significance, and sometimes the magnitude of an environmental aspect before you set performance targets.

For instance, some spills can disperse at a faster rate than others:  this means that you need to understand any potential sources or pathways for pollutants, proximity to spill kits, whether staff are trained and competent to rectify a spill, and how often checks need to be conducted. A classic example is to think about how quickly glue can travel in comparison to a solvent, which is sometimes called the “momentum” by our assessors.   

This should be backed-up with regular internal auditing or conformance checks at a suitable frequency. Indeed, many assessors prefer an element of auditor independence from the auditees. This is why it is important to clearly define the roles and responsibilities under an ISO 14001 management system. The process of auditing then becomes focussed on identifying anything that undermines environmental performance objectives, to identify risks to the environment, and to identify aspects of legal compliance.

For example, internal auditors should check that bunds around oil storage tanks meet 110% of the maximum capacity of the largest tank or drum because this is a requirement under The Control of Pollution (Oil Storage) (England) Regulations 2001. This is also why ISO 14001 includes a process for gaining and retaining information on legal changes and changes to other requirements, such as customer specifications.

Leadership

The third factor in your organizations environmental performance is usually focussed around leadership, and how this has functioned to enable change within your organization.  It is important to make employees aware of your environmental objectives and to provide regular updates so that they are informed of success, or ongoing challenges.

They need to understand how exactly that they need to respond to environmental incidents, and how they need to behave or work, in order to ensure that the organization meets its performance targets and continually improves.

Special consideration must be given to interested parties, like external stakeholders that could have an influence over the attainment of environmental performance objectives. One organization that springs to mind has an issue with dust pollution and will shut down when the wind change direction towards neighbouring properties - this information is sometimes communicated to external parties in order to reduce the magnitude of any complaints, should they be received.

Leaders have a wide range of functions within an ISO 14001 management system, and it is very important that environmental performance objectives (stating any achievements) are clearly reported in a regular management review meeting.

Review meetings should also consider the internal auditors report, external communications, third party assessment, preventative and corrective actions, changing circumstances, and a follow-up from the previous meeting.

Lastly, do not forget the importance of maintaining good records to demonstrate your organizations success.

ISO 14031:  Environmental Performance Evaluation

You might consider implementing some of the guidance provided by ISO 14031: Environmental Performance Evaluation. This standard supports ISO 14001 in providing guidance for the establishment of environmental Key Performance Indicators (eKPIs). These indicators are classified according to the nature of each environmental objective, for example:

  • Environmental Condition Indicators (ECIs) – e.g. Chemical content of local rivers,
  • Operational Performance Indicators (OPIs) – e.g. Emissions per unit of product,
  • Management Performance Indicators (MPIs) – e.g. Numbers of incidents.

This approach is particularly useful when all three types of performance indicators are used together. For example, some organizations have permission to discharge wastewater into watercourses:  in this instance we could consider monitoring:  a) the volume of pollutant discharges and the mean water level in the river as the OPIs, b) the chemical water quality and biodiversity within the river as the ECIs, and c) the response time to mitigate pollution incidents as the MPI. These five performance indicators would provide a cumulatively more robust method of environmental performance evaluation under ISO 14031.

Conclusion  

There are several requirements within ISO 14001 that enable improved environmental performance, and we have presented a few of the main concepts above. ISO 14031 is a very interesting standard if you are looking to reinforce ISO 14001 with a defined method of environmental performance evaluation. This is bound to be attractive to large and complex organizations that undertake environmental reporting and need to demonstrate their success to interested parties, and those that are more environmentally sensitive.