Expertise and the construction of relevance: Accountants and environmental audit

Pergamon

Accounting, Organizations and Society, Vol. 22, No. 2, pp. 123-146, 1997 c 1997 Elsevier Science Ltd Au rights reserved. Printed in Great Britain 0361.36B2/97 $17.00+0.00

PII: SO361-3682(96)00037-2

EXPERTISE AND THE CONSTRUCTION OF RELEVANCE: ACCOUNTANTS AND ENVIRONMENTAL AUDIT*

MICHAEL POWER London School of Economics and PoliticalScience

Ahtract have begun to compete for work in the environmental auditing field and this essay describes the strategies by which they have attempted to represent themselves as relevant experts. A shift in regulatory style has stimulated experimentation with new instruments of control, including voluntary schemes for environmental auditing which emphasise a management control system. Subsequent attempts to define the relevant knowledge base of environmental auditing and to accredit verifiers have created a stage on which accountants can promote their claims. The essay draws attention to the construction of an overlap between the skills required for financial and environmental auditing. In turn, this strategy requires that other forms of expertise, such as in the field of the applied sciences, must be subordinated within an audit process which is controlled by the accountant. 0 1997 Elsevier Science Ltd. All rights reserved Some accountants

Environmental auditing has many similarities with traditional auditing and the auditor has a long standing tradition of investigating and evaluating systems as well as reporting the Endings. It would therefore be expedient to take the auditing profession’s experience and methods as the point of departure. (Danish Auditing Profession quoted in FEE, 1993, p. 38)

has had much to do with their ability to expand into new areas of advice and mediation from a traditional base in auditing, tax and insolvency. In doing so they have succeeded, so far, in managing “shifting processes of commercialization” (Radcliffe et al., 1994, p. 602) and in maintaining “a coexistence between the ideology of public service and the logic of profit” (Dezalay, 1995, p. 341). In this way, accountants have become powerful social actors who, far from performing merely calculative and verificatory services, increasingly shape “the whole apparatus of intervention” (Dezalay, 1995, p. 338) across a wide range of activities and organizations. And corresponding to their role in mediation, accountants in the UK have also assumed a dominant position

the financial auditor can play a role in environmental auditing but possesses only one element of the required knowledge, skills and experience needed to carry out environmental audits. (FEE, 1993, p. 13) The term environmental audit.. is widely misunderstood as being akin to statutory financial audit. (ICC, 1991, p. 4)

The economic success story of accountants, and of the large accounting firms in particular,

*An earlier version of this paper was presented at the Interdisciplinary Perspectives in Accounting conference, Manchester University, July 1994. The author is grateful for the comments of Jim Haslam, Christopher Hibbit, Anthony Hopwood, Christopher Humphrey, Richard Laughlin, Peter Miller, Christopher Napier and two anonymous referees. The financial support of the Research Board of the Institute of Chartered Accountants in England and Wales is also gratefully acknowledged. 123

124

M. POWER

within management hierarchies at the expense of other forms of “control know-how” (Armstrong, 1985). One consequence of this success is that it has now become difficult to define precisely what an accountant is other than trivially in terms of membership of a professional body-which is in any case fragmented (Willmott, 1986; Sikka & Willmott, 1995, p. 550) and ill-defined (Kirkham & Loft, 1993, p. 508). While the set of auditors is becoming institutionally defined in Europe by virtue of statutory registers, the category of accountant remains problematic and diffuse, covering many areas of work in industry as well as public practice.’ The large accounting firms have become internally diverse and it no longer makes any sense to regard them as speaking with one voice on the question of accountants’ claims in different fields of work.2 In short, the boundaries between what is and what is not accounting are no longer, if they ever were, Iixed. Indeed, the “contemporary expansion of accounting practice is in many ways a return to its rather mixed origins” (Radcliffe et al., 1994, p. 624). Despite this complexity, we should not be blind to the strategic and rhetorical potential of the category of “accountant” and related terms in articulating and promoting claims of competence in new areas of work, even when these new areas have an uncertain economic potential. As Jasanoff (1987, p. 199) puts it, “boundary defining language” and ‘new conceptual categories” make possible the extension of interests into new or enlarged fields of work. An economic interest in a new area of work is not even a sufficient condition for establishing credible and legitimate claims to work in that area. Bather, market competition must be supported by a form of interpretative competition in the form of claims to expertise. This is especially so where the nature of the market and the competences to operate in it are ill-defined and immature. In such circumstances, even the

driest and most procedural elaboration of practical guidance is not simply neutrally descriptive; it is part of a wider normative discourse which constructs and presents the field in ways which make it receptive to the claims of a certain form of expertise rather than another. This means that the control of professional language in official documents, conferences and committees is a vital resource in jurisdictional competition (Abbott, 1988, p. 139). As Kirkham and Loft (1993, p. 508) have put it, “professionalization projects have discursively deployed concepts of difference and similarity.. . as a basis for inclusion and exclusion.” Hence, ways of talking about a practice are an important feature of the practice itself. This essay is concerned with the various representational strategies by which the relevance of accountants and accounting based expertise has been promoted in the context of emergent markets for environmental auditing. It should be emphasised that the analysis is about claims to legitimate competence in the environmental auditing market, not the market itself which is still developing. The environmental auditing field provides an example of how accountants and their representatives can articulate claims to competency in an area of work with which it may not be natural or, from some points of view, desirable to associate them. There has been much debate within industry about what environmental audits “really are” and in an attempt to bring greater determinacy to a diverse range of practices, regulatory attention has increasingly focused on the expertise base of environmental auditing practitioners. But environmental auditing know-how is not merely a question of semantics which can be resolved by better definitions of the practice. Such definitions are often the product of interpretive strategies to promote a relevant knowledge base which can be represented as overlapping with, and sufficiently similar to, other practices and skills. In the

’ For example, in Germany, it is not possible to talk of an “accounting” profession in the same way as the term is used in the USA and UK. 2 Recent controversy in the UK concerning the establishment of a tax faculty within the ICAEW is a case in point.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

blurred boundaries between different sources of expert authority, questions of technical content and the jurisdictional aspirations of experts go hand in hand. In the next section I consider specific regulatory initiatives in environmental audit, initiatives which reflect a broad shift in regulatory style. Questions of competence and knowledge in the environmental audit field crystallise around the function of independent verification of system operations. I argue that discursive competition with applied scientists and lawyers has as much to do with preserving hierarchies as with jurisdictional expansion. Although accountants’ claims to expertise in independent validation provide a conceptual bridge between financial and environmental auditing, the crucial issue is that of task orchestration. Finally, the strategies of accountants to establish lead expertise are considered in terms of: the similarity and difference claims which they advance; the role of audit as an abstract body of knowledge; and the subordination of science to accounting. Overall the paper suggests that the relevance of expertise in the environmental audit field is subject to competing constructions which seek to link it to established forms of practice (e.g. Coopers & Lybrand Deloitte, 1990, 1991).

THE RISE OF ENVIRONMENTAL AUDIT It is no longer possible, if it ever was, to distinguish between state and self-regulatory arrangements. While the latter are often implicitly sponsored by the initiatives of the former, the former are forging alliances with the latter. Attempts have been made to characterise this shift in regulatory style in terms of “responsive regulation” (Ayres & Braithwaite, 1992), “governmentality” (Rose & Miller, 1992) “self-

125

organisation” (‘Teubner et al., 1994) “mutual regulation” (Simmons & Wynne, 1994) and “reflexive law” (Or&, 1995). The general idea is that command philosophies of regulation are giving way to forms of control which utilise the cognitive and economic resources of the regulatee. Regulation is increasingly pushed down into organisations and their internal systems of self-assessment and control. In other words, internal control systems are being explicitly recruited into regulatory programmes with the hope of improving compliance.3 This shift reflects a “managerial turn” in regulation and is clearly visible in the environmental field (Hajer, 1994). The “shrinking state” has created revenue opportunities for management consultants as they take on the role of mediating regulatory compliance and economic strategy for their clients. Demand in these new “green markets” (Grabosky, 1994) has been constituted by a complex mixture of responses to existing and anticipated legislation, public opinion, peer pressure and, no doubt, the ability of management consultants to generate corporate anxieties (Iasch, 1979, p. 385).* Not surprisingly perhaps, critics argue that these changes only represent a “remanagerialisation of risk” (Beck, 1992) rather than its reduction; form rather than substance (Ost, 1994). But enthusiasts regard a more conciliatory style of regulation, which enlists third parties and their internal control systems, as a superior basis for ensuring compliance (Rous seau, 1988; Aalders, 1993). This regulatory optimism is reflected in the large number of semiofficial acronyms expressing an integrated logic of economic performance and environmental care.5 The emergence of environmental audit schemes typifies this shift in regulatory style. Originally transactional environmental audits (Gunningham & Prest, 1993, p. 495) emerged

3 For more on this regulatory shift see Power (1997, chapter 3). 4 The recent growth in environmentally related consulting in Europe has been conspicuous, now estimated at MO0 million per annum. See S. Foxon, Twenty Year March to the Plateau, Financial Times 21 June 1995. 5 For example BATNEEC, which stands for Best Available Technology Not Entailing Excessive Cost.

126

M. POWER

in North America as part of private contracts for the sale of land, business or for lending and insurance arrangements. These early forms of audit practice were shaped by an adversarial regulatory context and the need for the “creation of authority through legal notions of due process” (Smith & Wynne, 1989, p. 18). Accordingly, lawyers have typically orchestrated this work in North America and accountants have either been unaware or uninterested in the field (Specht & Buhr, 1994). As environmental regulation has developed more generally, environmental audits to determine with those regulations have compliance evolved (Palmisano, 1989; Van Cleve, 1991). Gradually, environmental auditing has emerged from its diverse and dirty origins in the private world of corporate transactions to connect with, and exemplify, broader regulatory sensitivities and agendas. Environmental auditing is being reshaped and appealed to as part of a regulatory strategy which seeks to internalise regulatory compliance through an integrated environmental management process (Bregman &Jacobson, 1994, pp. 221-23). Two environmental auditing schemes have dominated recent European discussion and debate: the Environmental Management and Audit Scheme (CEC, 1993)” and BS7750 (BSI, 1993).’ The structures of these two schemes have much in common although the former is a European Union initiative for industrial sites and the latter may apply to any organisation and, given its international counterpart in the International Standards Organization 14000 series, has no jurisdictional restrictions. Both are voluntary schemes for which organisations may register in order to obtain the perceived

benefits of official accreditation and publicity for internal arrangements. However, only EMAS provides for a (limited) form of public reporting, for which the opinion of an accredited verifier is required.’ The structure of both schemes centres on the operation of an environmental management system which repackages and re-presents many elements from existing strategic consulting repertoires: an initial review; the formulation of policy; the setting of environmental performance standards (benchmarking); the development of a system of internal control to monitor actual performance against standards; a form of statement on environmental performance (EMAS); the external and independent verilication of the workings of the system and, for EMAS, the statement of performance. These latter elements are crucial since they connect the internal workings of the organisation to the public values of the regulatory environment. Without the dimension of independent validation, these schemes would have some kind of economic value for organisations, in the same way that internal auditing does more generally, but they would fail to connect the organisation to more public regulatory structures. The management system is central to the the “managerial turn” in environmental regulation. In theory, regulatory and corporate aspirations coincide in the structure of such a system which serves economic and environmental goals simultaneously. Both auditing schemes have been designed with the intention that the benchmarking of standard practice will develop, ranging from legal compliance to “good” and then to “best” environmental practice. Forms of internal and external

6 The scheme was originally designed to be mandatory. Following extensive lobbying by industry, registration for the scheme was made voluntary. However, there remains the possibility that its status might change again, notwithstanding a regulatory preference for delegated regulation. ’ The European Union regulation for environmental impact assessment fEL4) is not discussed here, although it must be noted that many local government bodies, increasingly aware of their accountability to local publics, have developed auditing practices on the back of EL&s(see Boden et al,, 1993). s The environmental statement under EMAS must include inrer alz’u an assessment of aE significant and relevant environmental issues and a summary of figures for material and energy consumption and waste generation, together with any other significant effects. For a detailed analysis of these schemes, see HiRary (1993) and Woolston (1993).

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

consulting have responded to the need to assemble and reassemble the elements of the environmental management system to achieve this end. However, benchmarking processes and environmental management and audit schemes occupy separate institutional spaces: the auditing schemes only require that there be some standard or other and are silent on its content. Although the markets for these system based environmental audits are still developing, there has been pilot testing. In the context of EMAS there have been worries that “sites with very different actual levels of performance [will] be given equal recognition under the scheme” (Hemming, 1993, p. 5). These and similar criticisms echo longer standing concerns about quality assurance initiatives, such as BS5750 (Halliday, 1993), upon which BS7750 is based. Despite an explicit statement by the BSI that “BS7750 does not set out environmental performance guidelines”9, the criticism is that integrated environmental management ends up, for all its good intentions, emphasising a formal process relating the system elements rather than the standards to which the system and the organisation might be held to account. The problem exemplifies one of the fundamental trade-offs in the design of risk management structures: where uncertainty cannot be entirely eliminated, the traditional physical-standards approach needs to be supplemented or even replaced by an emphasis on specify@ organizational processes that will ensure careful balancing of arguments. Such an approach to organlsational design is exemplified by the philosophy supporting BS 5750. (Royal Society, 1992, p. 166).

The concern of critics is that the emphasis on formal process has in fact displaced, rather than supplemented, the traditional physical standards approach. In doing so the door has been opened to the claims of accountants. g See the BSI marketing pamphlet Introducing

Registration

127

It remains to be seen whether environmental audits are as tightly coupled to organisational processes as they aspire to be; this is an important researchable issue for the future. At a conference on EMAS and BS7750 in 1995, a spokesman for the NACCB, the UK accrediting body for environmental auditors, expressed a concern that “30% of the management system was created for the audit” and that there was a need to address substance rather than form in the implementation of these schemes.” The danger is that regulatory attention is deflected from “deep” organisational process towards chains of abstract procedure which substitute for more direct forms of control (Simmons & Wynne, 1992, p. 215). EMAS and BS7750 have also generated considerable debate over the nature and role of the “accredited verifier” (EMAS) or “independent certifier” (BS7750). Given the public stage on which environmental audits are to operate, it is maintained that the symbols of comfort provided by the external auditor will only have value where they are produced by a credible and independent authority. It is often on this question of independent validation that analogies with financial audit have been claimed (even though the independence of financial auditors has been discussed and criticised for as long as auditing has existed). For example, it has been argued that ethical characteristics similar to those offinancial auditors would be needed in the environmental field (CICA, 1992) and that the reliability of environmental disclosures in various media can be enhanced by independent verification (ICAEW, 1992, p. 108). A few companies, such as the Caird Group, British Airways and Norsk Hydro, have provided experimental forms of independent attestation in advance of EMAS and BS7750 schemes (See Gray, 1993, p. 252). The forms of disclosure which accompany these independent attestations are varied in scope and much to BS 7750 (London: BSI, undated).

i” M. Houldin, Accreditation Development, presentation at the Network for Environmental Management and Audit (NEMA) conference, Progress on EMAS Verification and BS 7750 Certification, London, BSI, 31 May 1995. The NACCB has subsequently been absorbed into the UK Accreditation Service (UKAS).

128

M. POWER

depends on the nature of the report whose detail is being verilied and on the nature of the opinion provided by the verifier. The Norsk Hydro report borrows the “true and fair view’ ’ terminology from accounting but this bears little relation to a financial auditing report. l l Concerns about independence have been relatively late to surface in the environmental auditing field for good reasons. Environmental auditing is primarily conceived as a “management tool” (ICC, 1991); it is an internal practice which has grown outwards to connect with regulatory programmes and which is experimenting with forms of external reporting. In contrast the external financial audit, starting from outside the organisation with the official aim of serving outside stakeholders, has needed to grow inwards and embrace internal systems of control as they have developed. Compared to financial auditing, concerns about independent validation and reporting are relatively recent in the environmental auditing field. One could put the point as follows: whereas external financial auditing has developed the ability to rely on internal auditing, environmental auditing is an internal practice which, in EMAS and BS7750, relies on an external verification function. It is important to keep these different normative

reference points in mind when discussing the independence issue. l2 It has been suggested that accredited verifiers will emerge as a new profession (Hillary, 1993, p. v) and that the “battle over verifiers is about to begin”.13 However, the profitability of working as an independent auditor in _ the environmental audit field is far from clear and the EMAS market is still in its infancy. Indeed, given industry pressure to avoid the duplication of internal audit work and the existence of rules for independence which seem stronger than those for financial auditors, the market for internal advice seems prima facie more attractive.‘* Because of the internal and private history of environmental auditing, independent validation is developing more as an “add on” or extra service. But if this is so, why has the external audit component of the environmental audit schemes attracted so much attention, particularly from accountants? In part different groups’ claims to competence as external verifiers have the form of an option: they do not know how the market will in fact develop but they wish to be positioned to service it. However, the issue also has much to do with the legitimacy that being licensed as an independent verifier will afford to practitioners. Put simply, this means that qualification

I1 See also A. Jack, Green Accounting and Competitive Advantage, Financial Tfmes, 19 March 1992. I2 In the Swedish context Almgren (1989, p. 67) suggests that new sensitivities about independence have emerged because internal and external inspection functions have become blurred, largely as a result of subcontracting to consultants who are also advising clients. The Institute of Environmental Auditors in the USA echoes financial auditing formulations by stating that objectivity is a “state of mind” though it differs in admitting that, if this is so, then internal audit arrangements can be independent in the required sense. Indeed, voluntary environmental audit practice tends not to invoke a rigid financial auditing distinction between internal non-independent and external independent agents. For example, Plaut (1989, pp. 7-S), in the context of the Health, Safety and Environmental Surveillance program at Allied Signal Inc., claims that the Corporate Audit department would have “a high degree of independence from health, safety and environmental program management-but would not have the needed understanding of the subject matter” (pp. 7-8). Such a statement suggests that, within the environmental auditing field, independence is just one value among others and can be satisfied by structuring internal arrangements. This contrasts with the central role that independence plays for the external Enancial auditor. r3 A. Jack, The Green Time Bomb, Ffnancid

Times, 31 March 1993.

‘* One important stumbling block to the claims of accountants as verifiers of environmental statements under EMAS is the imposition of independence requirements which are more stringent than those for financial audit. The NACCB (1995, clause 4) generally disbars verifiers from acting as consultants, although this does not apply in the “developmental phase” when a “transfer of expertise” is desirable. Such rules will restrict the opportunities for accountants, in the UK at least, to work as verifiers unless organisational structures and “chinese wall” arrangements can be designed to satisfy regulatory misgivings.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

as an accredited verifier, recognised by the appropriate state delegated body under EMAS, will provide added credibility for those engaged in the market for expert mediation more generally. It is not that accountants or others will always wish to work as verifiers but that the entitlement to do so provides an edge in the market for advice more generally. This means that independence is a stake in the market for professional advice and that the rhetoric of independence “plays a productive role in organizing and legitimizing relations of power” between different professional groups (Robson et al., 1994, p. 532) and in securing and expanding the accounting jurisdiction (Sikka & Willmott, 1995, p. 550). To obtain state recognition of a capability for independent validation is to assume a certain position in the market for expertise, a market in which the creation and preservation of bierarchicuZ structures of practice is more important than the maintenance of boundaries between different fields of knowledge. This point, which is crucial to understanding the claims of accountants in the environmental field, will become clearer as the multidisciplinary nature of environmental auditing is considered.

MULTIDISCIPLINARY IDEALS AND THE INSTITUTIONAL INDETERMINACY OF EXPERTISE It has become widely accepted that environmental auditing requires a multidisciplinary approach. l5 For example, one must “seek to build audit teams with an appropriate mix of skills” (ICAEW, 1992, p. 112). Similarly, there is a need for a “multidisciplinary team of scientists, engineers, lawyers and accountants” (FEE, 1993, p. 12) for “lawyers. .engineers,

129

chemists, hydrologists, geologists, biologists and other scientists” (Salter, 1992, p. 149) who “possess a mixture of technical, management and environmental legislative skills” (Hillary, 1993, p. 36). Exactly “which disciplines the external auditors will be drawn from. .remains up in the air” (Sanehi & Waire, 1991) but they will need “experience of working in multidisciplinary teams” (Huizing & Dekker, 1992, p. 444). Their knowledge base “could include, but is not restricted to, management information systems, engineering control systems, management systems, accounting, finance, statistics and the law” (TEA, 1991). Veldhuizen (1989, pp. 80-90) describes the environmental auditing programme of Noranda Inc. in which auditors are drawn from “chemists, engineers, environmental management scientists, industrial hygienists, medical doctors and nurses, and process, transportation and emergency response experts.” At Norsk Hydro (Syrrist, 1989) the audit team consisted of an engineer, a systems auditor and a production manager. And in the context of physical ground investigations it has been stated that “many organisations do not have in-house expertise. . .A profusion of professions claim to possess expertise in such matters, but the most complete picture will often be obtained Erom a multidisciplinary approach” (Dennis, 1993, p. 23). Dewar argues that “the natural reaction perhaps is to see such work as being the province of environmental scientists, process engineers or those with similar skills. The discipline of accountants and auditors may appear less relevant” (Dewar, 1993, p. 10). But, like many accounting based practitioners, he argues for the skills of accountants in the field of systems work, financial implications and their emphasis on the importance of “hard evidence”, an irony given the traditional association of science with such a claim.

I5 See, for example, B. Maddox, A Multidisciplinary Field, Financial Times, 10 November 1992, which approaches this issue from the point of view of choosing an environmental advisor. It ought to be borne in mind that the environmental audit field is not alone in this respect. For many years government audit work in the USA and the UK has been subject to demands for a multidisciplinary approach.

130

M. POWER

The problem with these and many other similar claims is that they are essentially technocratic in form and assume that the problem for environmental audit is that of coordinating different functional specialities. Appeals to multidisciplinarity also tend to assume the stable identity of different bodies of knowledge which can then be brought together for a specific purpose. In other words the rhetoric of multidisciplinarity represents different disciplines as discrete, technical practices and ignores the forms of reductionism in applied settings (Smith & Wynne, 1989, p. 7) through which particular forms of expertise become dominant. Furthermore the widespread appeal to multidisciplinarity often disguises the sense in which new fields with new objects are created as initially temporary alliances of expertise begin to stabilise and to become institutionalised. This is evident in the formation of other “hybrid” fields such as industrial relations, palliative criminology and, more recently, medicine. Experts in multidisciplinary teams can only work in varying degrees of superiority and subordination. In terms of professional and market aspirations what matters is less who does the majority of the work and its skills base but who is the institutionally legitimate orchestrater of this work. Guidance by the NACCB (1995) for the accreditation of environmental certifiers (BS7750) and verifiers (EMAS) explicitly allows for work to be subcontracted. Accordingly, the question for ecoaudit expertise is as much about who controls and leads the process as who does the “nitty gritty”.” At the extreme, power and economic rewards may accrue to experts who merely act as brokers and subcontract large portions of work:

The export-or import-of a specific expertise is indissociable from the export-or import-of the hierarchy of knowledge in which it is found to be inscribed. Thus, to import the model of the North American lawyer is implicitly to adopt a social set-up which enables this professional category to lay claim to the role of orchestra conductor in multidisciplinary teams (Dezalay, 1995, p. 338).

Certainly, lawyers have been an integral part of emerging environmental audit practices (e.g. Riesel& Zarin, 1991). Abbott (1988, p. 126) makes a similar point when he argues that super-ordinate groups will rid themselves of “dangerously routine” tasks which threaten their collective mobility aspirations. But what is “dangerously routine” in the context of environmental audit is relative to a particular field of expertise and its need to preserve its position in the hierarchy of professional knowledge. For example, Salter (1992) suggests that the role of lawyers in environmental audit may extend to the selection and coordination of the work of the team. And where the interpretation of legal documents is regarded as central to the audit process then lawyers will be crucial (Sanehi & Waire, 1991).” More generally diierent experts will see the routine/non-routine distinction in different ways and will frame the environmental audit task in such a way as to represent their own work as super-ordinate and non-routine. As Dezalay puts it, “the stakes in [a] rapidly expanding market are more hierarchical than territorial The objective is not to eliminate the competing know-how but to absorb it” (Dezalay, 1995, p. 339).

Two interrelated areas where the framing of environmental auditing know-how is taking institutional shape involve the development of

I6 cf. “It is not so much the development of a new profession that is the question but how existing professionals and consultants should work together” A. Carey, head of international accounting at the ICAEW, quoted in “Who will be Green Auditors” Accountancy Age 2 September 1993, pp. 6-7. I7 See R. Rice, A very profitable practice, Financial Times, 15 September 1991, who recites the standard joke that the only cleaning up being done under the Superfund legislation is by lawyers. More interestingly, it is the recontiguration of expertise in relation to regulatory initiatives which is evident in the behaviour of lawyers: “many of those ciairning to be environmental lawyers are pkuming lawyers or conveyancers or company lawyers wearing a different hat but offering the same advice”.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

standards for environmental audit practice and the accreditation of environmental auditing practitioners. Environmental auditing standards Pilot studies of EMAS indicate that there are concerns about the cost-benefit function for the external verifier (Hillary, 1993; Hemming, 1993) and the need “to avoid unnecessary bureaucracy and duplication of the work of the auditor. We hope that in principle the verifier should act like a financial auditor” (Van Ropenack, 1993, p. 8).18 Once again, these concerns reflect the “management tool” orientation of environmental auditing discourse. It has also been suggested that “the verifiers are pioneers groping around in the dark with few guidelines to help them form a view”.19 EMAS pilot studies have exposed the fact that the regulation lacks any specification of a detailed audit methodology other than general references to “appropriate expertise”: “Defining auditors skills.. .is difficult because there are no recognised standards” (Hillary, 1993, p. 36). If there really is to be a new environmental audit “profession”, its personnel and skills are as yet indeterminate and vague (see Huizing & Dekker, 1992, p. 444, fn. 15). This indeterminacy has led some commentators to claim that environmental audit may be “anything you want it to be” (Gray & Collison, 1991, p. 17) and that there is “no universal methodology” (Elkington, 1990, p. 5). New forms of environmental accounting, such as registers for contaminated land which might render a new domain of “green facts” visible, and the reporting of financial liabilities (e.g. ICAEW, 1995) remain controversial. Even non-accounting commentators have drawn attention to the “professionalism” and “standards” of financial as compared with environmental auditing. It has been said that the lack of professional standards both for sam-

131

pling and clean up of contaminated land has allowed “a minority of unprofessional and inept consultancies to offer services of a substandard quality immune from a charge of negligence (because negligence requires standards and here there are none)” (Sykes, 1993). More generally, “An unplanned pattern of development has raised concerns about the quality of environmental audits” (Grayson, 1992, p. 23). Thus, notwithstanding the problems currently faced by financial auditing, relative to the field of environmental audit its authority and standards can be used as a professional model. And even though the increasingly detailed regulation of financial auditing and accounting practice is questioned by many accounting practitioners (Coopers & Lybrand, 1994; KPMG, 1995) it nevertheless provides a basis for claiming a history of competence in independent attestation and reporting which can be extended to new areas such as environmental audit. Many of the demands for standards simply assume they can be articulated and codified in a determinate fashion. One of the most extensive attempts to do this so far is the draft code of practice for environmental verifiers produced jointly under the authority of the European Commission and the UK Department of the Environment, published by the Judge Institute of Management Studies at the University of Cambridge and written by an individual seconded from Environmental Resources Ltd, an international consultancy (CEC DG XI/UK DOE, 1993) The absence of any reference to ERL in this document is an example of the effacement of origin as a source of legitimacy. In addition, the network of alliances involved in its production epitomises the manner in which regulatory knowledge production is increasingly sub contracted. Although the document has been superseded, and new guidance is being drafted at the time of writing (CEC DGXI, 1995 uuly]), its

‘s See also A. Jack, Quality Concern, Financial Times, Survey otl Environmental Management, 22 December 1993. Such questions of cost-benefit are equally relevant in the case of the external financial audit. However, it has a longer history and has not been subject to “pilot” studies in which such questions could be raised. I9 See, Body Shop Treads Thin Green Line, Financial

Times, 26 May 1993.

132

M. POWER

style is indicative of the increased juridzjkation of risk management (Royal Society, 1992, p. 152) in which the proceduralization of practices has taken place in advance of agreed standards both of substantive environmental performance by enterprises and by auditors themselves. The document provides little indication of the skills base of various activities. Bather, there is a legalistic matching of the structure of the EMAS regulation to more elaborate procedural guidance. In effect, this is a bureaucratic solution to a problem of knowledge which assumes that the original drafters of the regulation (lawyers) had a clear conception of the environmental audit process. As far as the role of the external verifier is concerned, there is considerable emphasis on the need to assess the experience and competence of the internal “environmental auditor”. This tradition of auditing by reliance on the work of other specialists is well established in the financial auditing field and enables complex areas to “become auditable” by focusing upon the credentials of practitioners (an input) rather than on their knowledge base (the output) directly (Power, 1996). The guidance document also stresses the importance of “technical environmental competence”, “specialist capability” and local knowledge of “site operations”, but these categories receive no further elaboration. Overall, the document has the appearance of being more than a statement of principles but much less than a form of detailed guidance. Perhaps because of this, and because of its length, it has not won acceptance on the European stage. Current fashion, in the UK at least, is for general principles at the level of the regulatory authority (NACCB, 1995) which enable the development of detailed guidance at the practitioner level. It seems likely that the successor document will adopt this approach; a certain vagueness in the specification of guidance is essential to the “practical logic” (Bourdieu, 1990, p. 77) of an expert field and

vests the power of interpretation and evaluation in practitioner bodies themselves. It is perhaps symptomatic that a recent book with the title “Zmplementing an environmental audit” (Ledgerwood et al., 1994 emphasis added) explicitly avoids the “technical depth required for environmental audit” (p. 2), preferring the higher level language of total quality management. Accordingly, whatever the exact division of labour between regulators and practitioners in writing environmental audit procedure, this so-called guidance cannot always be taken at its technical face value; it plays an important role in institutionalizing the field of practice, making its practitioners credible and, importantly, formalizing the field in such a way that “transforms a practical pattern into a linguistic code of the juridical type” (Bourdieu, 1990, p. 82) which is “symbolically effective” for the practice in question. Or, in Abbott’s terms, expert action systems require formalizations of this kind if they are to rise above the perception that they are merely “craft knowledges” (Abbott, 1988, p. 103).2O Regulating environmental auditing practitioners The codification of procedure, such as the EU is seeking for environmental auditing standards, is not simply a descriptive reflection of existing best practice but also an “ontological transmutation” (Bourdieu, 1990, p. 81) which locates the practice in a new public space where the specification of knowledge and the regulation of practitioners go hand in hand. In the UK a number of accreditation schemes for environmental auditors have emerged. Indeed, there has probably been greater activity in the area of regulating practitioners than in the development of technical guidance for them. In “inscrutable markets” (Gambetta, 1994) where it is difficult for consumers to tell directly whether the product or service is a good one,

*’ Some representations of environmental auditing knowledge are case oriented (See e.g. Elkington, 1990). Such an emphasis on the local and specific regards “craft” experience as the key to credibility. In Abbott’s terms, without articulation in abstract terms and linkages with higher knowledge, this is no basis for a collective mobility project.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

mechanisms for securing the reputation of the practitioner (such as licensing) play an important role. These schemes seek to articulate the necessary competences of practitioners. For example, a trade association with its origins in water the Environmental Auditors management, Registration Association @LEA), formed a training subcommittee to develop a draft list of competences for environmental auditors (Hunt, 1993). Although accountants and accounting have no representation in this scheme, it makes reference to general knowledge of different audit types and a draft syllabus and exam system include one paper on “auditing skills” (the others are environmental management systems, legislation, environmental effects and performance).*i The UK Association of Environmental Consultancies has also developed codes of practice and an accreditation scheme for environmental auditors.** Both these schemes have sought official recognition at national level for the EMAS regulation. Accreditation projects like these are driven ostensibly by a concern with rogues (Dean, 1993) but they also reflect “collective mobility projects” by various associations which have emerged as a result of the managerial turn in environmental regulation and which now wish to consolidate and legitimate their authority by seeking state recognition. There has been talk of a bewildering array of professional bodies (Caine, 1993) in which “environmental auditing’s status as a profession is controversial” (Priznar, 1990),23 especially as verifiers will be subject to regulatory control but environmental consultants will not.** The rhetoric of multidisciplinarity is common to all these accreditation schemes, so there is no visible attempt to define environmental auditing know-how in

133

exclusive terms; such a project would have no credibility. However, the writing of the knowledge base of environmental auditing tends to take a form in which particular applied sciences are displaced by higher level management ideas: quality management, systems components and so on. Such abstraction in the representation of environmental auditing knowledge enables accreditation schemes to appeal to a wide and diverse body of existing practitioners, thereby providing for an association which is not obviously sectional. However, this is a strategy which has its weaknesses too. Abbott (1988) has suggested that an abstract codifiable knowledge base is an important ingredient of any collective mobility project. By implication there may be an optimum level of abstraction in which knowledge specification is neither too vague, thereby threatening claims to monopoly, nor too specific, thereby creating pressures for differentiation and fragmentation. Whatever the problems of defining and observing such an optimal abstraction, it seems apparent that in the environmental auditing field in the early 1990s many different groups and their respective forms of knowledge are claiming relevance, not so much in terms of the eJcclusivity of their know-how but in terms of their ability to orchestrate. Hence the battleground between management, legal and applied scientific specialties is not to do with “turf’ in its traditional sense; none can claim exclusive preeminence because the need for multidisciplinarity is so well established. Rather, it is to do with hierarchical relations in the market for expertise. To summarise: environmental audit is a practice in search of institutional closure. It is not so much that the constituent elements of environmental auditing skills are indeterminate in

” It is worth remembering that educational and instructional structures are never precisely isomorphic with the practical fields to which they relate. However, they are nevertheless part of a symbolic field in which practice is aligned, albeit in a loosely coupled manner, with hyper-rationalised bodies of knowledge (Abbott, 1988, p. 56). zz Code for Green Advisors Launched, Financial

Times, 5 May 1993.

23 See Oliver (1989) concerning the registration system for environmental assessors in California. 24 Put to the Green Test, Financial

Times, 12 May 1993.

134

M. POWER

themselves, quite the opposite is true; it is rather that the relations between them have become an important professional stake. Furthermore, the managerial turn in environmental regulation, which sets the tone for environmental auditing, favours a form of hierarchy in which management skills, broadly defined, control the process from the top. In turn, this preconstruction of the field is an opportunity not merely for accountants to stake a claim on a particular type of work, although some accountants may wish to do this, but also to reassert their position in the hierarchy of independent advisory expertise. The strategies for achieving this will now be considered.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT The relationship and “overlap” between financial and environmental audits has been widely discussed (See IFAC, 1995, p. 11). Not only are these debates informed by different ways of representing the knowledge base of the respective audits, they also depend on the institutional proximity of accounting representatives to environmental management policy circles. Accounting associational bodies, in the UK at least, have been relatively late to respond to the market possibilities as accredited verifiers, although parts of the consultancy arms of some large firms have been active in the market for internal advice. Three schematic and related strategies can be identified within the environmental auditing field which serve to promote accountants and accounting based skills. The first is a general territorial strategy of establishing sufficient similarity between accounting know-how and environmental auditing in order that accountants have a prima facie claim to relevance. The second and third have complimentary hierarchical objectives: to position auditing as a discrete body of knowledge at the highest point in the environmental auditing

skills base and, correspondingly, to subordinate the claims of applied science to occupy that role. Territory, similarity and difference

The ICC have drawn attention to -parallels between financial audit and environmental audits; a “standard methodology, an emphasis on verifying compliance against standards, and the use of some auditing techniques” (ICC, 1991, p. 4). But they also point to differences. The financial audit is statutory, annual, verificatory, external, based on GAAP and focused upon financial accounting whereas environmental audits are voluntary, of variable frequency, managerially oriented, internal, relative to varied standards of performance and focused on environmental issues. It was suggested above that these different starting points shape thinking about the respective fields. For example, the chemical industry has a long tradition of internal environmental management (e.g. Graham-Bryce, 1988 on Shell; Cowell, 1989 on BP). The “external” audit of the BP environmental statement by Ernst and Young, albeit in terms that are weak by comparison with financial auditing, indicates a spirit of experimentation in adding a public reporting function to this tradition (BP PLC, 1993). Perhaps it is natural to seek this additional benefit from the incumbent financial auditors but it also raises the more general question of the relevance of accountants to the environmental audit process. The potential for accountants to act as environmental verifiers and certifiers has become an increasingly prominent theme in the UK and elsewhere.25 This is a potential whose articulation and justification requires the acceptance that financial and environmental audits are “similar” in crucial respects. Such claims to similarity are far from being uncontroversial and there is considerable competition for credibility in the evolving environmental auditing market in which an older network of

*5 See A. Jack, Accountants Cash In, Financial Times, 10 November 1992. Jack suggests that insults about competence are being traded between traditional players, such ADL, and the new boutiques established by the large accounting firms.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

environmental consultancies is facing up to the relatively new “boutiques” offered by the Big Six accountancy firms. These developments illustrate how regulation may be the basis for creating and accelerating inter-professional competition. In a call to arms, Stittle says that “if accountants fail to grasp this opportunity, there are many other types of organisation that wiIl take up the challenge” (Stittle, 1992, p. 21). ERL, a non-accounting management consultancy, have argued that accounting firms cannot verify under the EMAS arrangements unless they can also provide advice on systems: “Accounting firms won’t be qualified to give advice to get companies to the right environmental standard. And we have prepared criteria for verifiers which the EC is debating”. In response accounting firms have been quoted as arguing that audit methodology is a specialist skill and that “companies will look for credible verifiers. . .eighty percent of problems are management or attitude rather than technical.” The environmental audit is the “natural adjunct to the financial audit. We can subcontract very technical assignments.“26 A number of studies have addressed the relevance of accountants directly. Huizing & Dekker (1992, p. 441) consider the particular case of the audit of a materials register and ask whether Dutch accountants may be capable in this field given the widespread belief that they lack the necessary “technical, ecological, adminis trative, juridical and organisational expertise”. Other Dutch accountants believe that they can in principle audit materials registers and can make judgements about the integrity of systems which generate “green reports”. Huizing and Dekker’s analysis addresses the different perceptions of the Corporate -Wide Environmental Care (CWEC) initiative and its implications for the potential role of chartered accountants. Changes in potential corporate liability clearly affect accounting directly and environmental groups and employee organisations in the

135

Netherlands also see a role for the accountant in auditing compulsory green reports. But, in opposition, the Dutch employers federation argues that the chartered accountant is a “superfluous link” between government and the company (Huizing & Dekker, 1992, p. 436). The employers are sceptical about the measurement of materials which is a “technical issue” (Huizing & Dekker, 1992, p. 437). Another similar idea comes from the Limperg Institute in the Netherlands which published a discussion document, Milieu en accountant, an important reference point in debate about the role of accountants. The report addresses three principle questions: 1. Is environmental auditing the domain of the traditional independent auditor? 2. Is it possible to develop a registration system for pollutants? 3. Can the financial auditor issue an opinion on the environmental report? It concluded that the financial auditing pro fession can make an important contribution to the training of environmental auditors and to the implementation of environmental audits. However, the authors of the report also suggest that environmental verification should be made by a specially trained environmental auditor rather than a financial auditor. The Limperg Institute’s study group has drawn up a protile of a member of this new profession. An environmental auditor should be well versed in the design of accounting systems and internal controls, includiig the methods and techniques used to measure and verify variables (the basic principles of financial auditing). The fmanciaf audit profession can make a meaningful contribution to the training of environmental auditors. The working relationship between the financial and environmental auditor would be similar to that between the auditor and the actuary of an insurance company’s pension fund (Blokdijk & Drieenhuizen, 1992, p. 442).

26 See, New EC Rules Spark Green Audit Spat, Accountancy Age, 1 April 1993, p. 2; Firms Ready for a Fight to Win Eco audit Work, Accountancy Age, 8 April 1993, p. 13.

136

M. POWER

This last point is important and reflects a strategy which is visible in other debates.*’ Financial auditors’ potential role in environmental auditing is normalised by analogy with other areas where they have worked with nonaccounting specialists, a point which will be developed further below. Different conceptions of the potential role of accountants are also evident in a survey by the Federation des Experts Comptable Europeens (FEE, 1993). Notably, in Denmark the Institute of Statutory Authorised Public Accountants (FSR) has led discussions with the explicit aim of establishing an “environmental audit profession”. This initiative conceives of the environmental audit as a “new task” with which no existing profession is fully equipped to deal. In November 1994, FEE and the FSR organised a workshop entitled “Environmental stewardship and management: positioning the accountancy profession” and, given the location of the European Environmental Agency in Copenhagen, Denmark seems likely to become a centre for debate. That the accountancy profession in Denmark has positioned itself as an important voice in this debate is also likely to be significant for the claims of accountants throughout Europe. Elsewhere, accountancy institutes have been less proactive. In Germany, the starting point for the Instittit der Wirtscbaflprti~er is the issue of how to quantify environmental liabilities and in countries such as Sweden environmental auditing is outside the domain of accountants (FEE, 1993, p. 41). Here there is a longer institutional history of concern for environmental management in which accountants have not been relevant and they have no institutional foothold in the environmental auditing field (see Almgren, 1989). In the UK Gray (1993, p. 96) suggests that “the professional accountancy bodies have shown little or

no interest” in developments in environmental audit and verification although “the accountancy profession is, in theory, ideally placed to oversee the environmental audit profession” (Gray & Collison, 1991, p. 24).28 However, the ICAEW recently formed a task force to address the possibility that accountants may work as environmental verifiers. This body has been less concerned with the interface between environmental and financial audits and more with negotiating the position of accountants as credible environmental verifiers, even though the market stakes are uncertain. One strategy for doing this has been to distinguish the reporting element of EMAS from that of BS7750 and to claim that accountants have a comparative advantage in this area. Whereas the NACCB regard BS 7750 and EMAS as essentially similar because they wish to regulate them in the same manner, accountants, who are less interested in certification work under BS7750, regard the two schemes as essentially different. What is to be concluded from these and similar discussions about the role of accountants in the environmental auditing field? A distinction between two issues may be helpful. First, there are concerns about the impact on the scope of financial auditing of environmental matters and about whether existing guidance is sufficient. Second, there are questions about the ability of financial auditors to provide environmental audits. These two issues pull in different directions and accountants in different countries have diverse starting points and background assumptions. The tendency in the USA, UK and Germany is to focus on the first concern, i.e. on how the financial auditing function can deal with environmental liabilities (e.g. Zuber & Berry, 1992). There is some evidence that financial auditors, with an eye on their own liability difficulties (Specht & Buhr,

” For example, in the case of brand accounting, proponents argued that the use of valuations for bmnds was no more contentious than for land and buildings (see Power, 1992). However, following the collapse of a number of property companies, property valuation practices have become controversial and new professional guidance for valuers has been issued. as See Gray et al. (1995) for a consideration of the more general absence of action by accountants in environmental reporting, despite their recognition of its emerging importance.

ACCOUNTANTS

AND ENVIRONMENTAL

1994) are reluctant to go beyond this and embrace new auditing and reporting roles. In contrast, auditors in Canada and Holland, where thinking has influenced suggestions in the IFAC (1995) report, seem to have shown greater enthusiasm for considering the overlap and similarity between financial and environmental audits, even to the point where they might be integrated. Accordingly, the boundary of financial audit practice is subject to different perceptions and the territorial ambitions of accountants in the environmental auditing field are far from being univocal across countries and even within firms. The discourses which represent and promote accounting competence have emerged in very specific places, such as sub committees of professional institutes and sections of the large Iirms. They are still far from being univocal or representative of the interests of the profession as a whole and are much more local than is readily apparent. In addition, uncertainty about the economic rewards from the environmental audit market persists. For all this specificity and locality, the general point still holds: different representations of environmental auditing and financial auditing know-how are in play which have different implications for the plausibility of accountants’ claims to relevant expertise in the area. However, more is at stake than just relevance per se. Beneath the orthodoxy of multidisciplinarity which may (grudgingly in many cases) concede a role for accounting type skills, the real question is the control and orchestration of the environmental auditing process. For this, much depends upon positioning auditing and reporting in a position of superiority to other bodies of knowledge. Auditing knowledge and abstraction Throughout discussions and debate about the nature and scope of environmental audit, attempts have been made to abandon the word “audit” and to talk in a more differentiated fashion of reviews, surveys, assessments and so on (e.g. Welford, 1992, who distinguishes many types of environmental audit). Some companies

AUDIT

137

“have deliberately chosen not to use the word audit, sometimes at the expense of legal or financial staff. Others use “audit” specifically to lend credibility to their programmes” (ICC, 1991, p. 4). It was suggested above that the relatively abstract nature of BS7750 and EMAS, their emphasis on management systems elements, makes possible claims to relevance by a broad range of experts, including accountants. It follows that the less abstract the representation of environmental auditing practice, the more that managerial disciplines like accounting lose their orchestrating foothold in the field. For example, Lovelock (1993, p. 33) addresses the knowledge requirements for landfill auditing in terms of geology and hydrology, landfill design, leachate and landfill gas production, migration and control and then, almost as an afterthought, management principles. Because of this, the strategic question is whether auditing is necessarily integrated into different applied skills or whether it can be made to stand alone as a discrete body of knowledge, common to financial and environmental contexts. The Danish accountants distinguish between “auditing knowledge” and “environmental technology”, a distinction which is clearly important in establishing the claims of accountants by promoting auditing as a body of knowledge in its own right. However, while one might expect accountants to argue that auditing is a discrete discipline and nonaccountants to oppose this, in reality the issue is more complex. For example, Ashmore and Stone (1993) describe the emerging arrangements for an eco-audit specialist register of the Royal Society of Chemistry in the UK. They argue that such specialist registers are initially constructed by means of a functional analysis of the skills base in question. In the case of ecoaudit, Ashmore and Stone identify audit and verification as distinctive functional skills but have little to say on the substance of competences required. Other non-accountants have argued that the environmental audit is a specialist activity but that the best specialists will be

138

M. POWER

generalists; there is a “non-trainable audit character” (Hill, 1993).29 The real issue is less the acceptance of auditing as a discrete set of skills in which accountants have a comparative advantage. It has more to do with the implications of this for the orchestration of work. Perhaps one of the best examples which illustrates construction of both accounting relevance and priority in the environmental auditing field, other than the Limperg Institute study, is the 1992 report by the Canadian Institute of Chartered Accountants (CICA, 1992). This document explicitly attempts to determine areas of overlap between financial and environmental audits and to evaluate the expertise of accountants which might be relevant. In order to do this it defines both the nature and scope of environmental audit and the skills of financial auditors and accountants, thereby constructing an “overlap” of skill~.~~ The CICA use a “narrow” definition of audit to make the analysis “manageable” (CICA, 1992, p. 34). It is a definition of audit which makes particular similarity and priority claims possible; audit is the “systematic process of objectively obtaining and evaluating evidence regarding a verifiable assertion about activities and events to ascertain the degree of correspondence between the assertion and established criteria and communicating the results (of the process) to interested users”. Expressed in such terms, accountants can stake a claim for a lead position in verificatory work of a diverse nature by appealing to their existing institutional role. This emphasis on the reporting function by the CICA resembles the position of the ICAEW task force and helps to define

“auditing” in a manner which reflects public conceptions of existing financial audit practice. The CICA document explores the “relevance” of accountants by analysing the skills necessary for environmental audits and yet it is also a normative document. By representing auditing as a discrete body of knowledge in its own right, accountants can “score” very highly in terms of relevance (e.g. ClCA, 1992, p. 60). In this manner, the CICA carve out a domain for the accountant and an overlap with many, but not all, environmental audit tasks. The apparent objectivity and analytical rigour of the matrices and tables in which this is done should not obscure the fact that these tables are a form of visual rhetoric. The construction of relevance in the CICA report has much to do with ways of representing tasks, skills and points of comparison. It has also much to do with the suppression of differences. The report argues that the skills of CAs are low in relation to environmental laws and regulations and low in relation to science, engineering and applied techniques. However, by listing skills which the accountant has but the engineer may not, the “gaps” in CA competence can be represented as minimal and may, crucially, be overcome by subcontracting. For example, the report states that accountants are unlikely to be able to do investigatory work or assurance type services where there is no “basis for a verifiable assertion” (CICA, 1992, p. 65). Accordingly, they conclude that accountants will not be central to “site assessments” and “operational compliance” matters but their traditional attestation skills are relevant to environmental management systems assessments (see also Specht & Buhr, 1994 on this point).31

ay Very similar claims are, and have been, made in the context of financial auditing. There are often debates about the merits of formally structured audit methodologies as compared with professional judgement. 3o Of course, comparisons between financial and environmental auditing may have implications in both directions. For example, when the CICA Report states that “it is sometimes difficult to know exactly how much assurance to take from environmental audit reports.” (CICA, 1992, p. 32) it should be remembered that the same has been said of financial auditing. Indeed, environmental audit reports have been compared favourably to financial auditing for their greater information value and critical tone, even though they may be “idiosyncratic and self-promoting”. See, Body Shop Treads Thin Green Line, Ffnancfal Times, 26 May 1993. 31 The Canadian Standards Association (CSA) has developed an auditing guideline on the back of this systems concept, although it is generally weaker than either EMAS or BS7750. Criticisms by Gale (1995) suggest that abstraction can go too far in the formulation of guidance.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

This brings us back to the crucial role played by the internal environmental management system in providing a platform for accountants’ claims. Without this the knowledge base of environmental audits would escape the horizon of accounting knowledge, as CICA admits it does for “site assessments”. The management system provides a role for accountants subject to a vague requirement for “sufficient knowledge of environmental matters”, knowledge which is not in principle closed to them. And the system provides an organisational reality on which audits can act (Power, 1996). The verifiable assertion, and hence the audit process, is shifted from the natural environment to the workings of the management system. This point has not been lost on internal auditors who also see themselves as experts in “systems thinking” (Wade, 1995, p. 26). For example, the Institute of Internal Auditors @A, 1993) has argued that the environmental audit is no different in approach from that of any other audit; elements of an environmental management system are common to any internal control system. But how common? The IFAC (1995) report, while accepting “some overlap” between operational, EMS and financial reporting control procedures, states that “most procedures on EMSs are, as with operational controls, generally outside the area of financial reporting controls normally considered in an audit of financial statements.” (IFAC, 1995, p. 11). Hence, (internal and external) financial auditors’ claims to relevance or non-relevance in the environmental auditing field boil down to views about the similarity between an EMS and other internal control systems, such as for quality assurance (Sammalisto, 1995). The more abstractly the EMS is conceived, the more that differences can be suppressed. To summarise: it is not only accountants who speak of auditing skills as if they formed a discrete body of knowledge. But the category of “audit” and the auditable object as a system of controls provide a crucial platform for their claims to relevance in a way that they do not for other experts. However, the articulation of auditing and systems know-how as discrete

139

fields in which accountants have a foothold is only one part of the construction of relevant expertise. At the same time, bodies of knowledge which are remote from accountants must be recognised and subordinated in some way. It is to the representation of non-accounting knowledge that the argument turns in conclusion. Accountants and the sub-ordination of scient@c expertise In all these debates about the actual or potential overlap or similarity between the component tasks of environmental and financial auditing, the rhetoric of “technicality” functions in at least two important and different ways. On the one hand, it is used to exclude those who are not applied scientists: management consultants Arthur D. Little conceive of necessary skills in terms of a “technical training” that includes knowledge of regulations and the familiarity with operational matters, such as hazard identification techniques, which engineers, chemists, safety professionals and industrial hygienists will have. On the other hand, accountants appeal to the merely technical, as something which can be subcontracted and does not threaten the similarity claims they wish to promote. As Abbott (1988, p. 25) puts it, the “subordination of routine work” is a “characteristic strategy of professions claiming more jurisdiction than they can serve” (see also Armstrong, 1985, p. 134). These demarcation lines in the market for expertise should not be oversimplified. Just as the category of “accountant” requires much greater analytical and critical refinement, much the same can be said of “science” and “scientific expertise”. Many non-accounting based consultants with applied science backgrounds now work for large firms of accountants and are arguing the accounting cause. Furthermore, accredited applied science training may play a minor role in the majority of technical work performed by non-accounting consultants since irrelevant learning is an important component of occupational associations (Abbott, 1988, p. 68) and education systems and practice are often loosely coupled.

140

M. POWER

Despite these complexities, a certain rhetoric of accounting and science is played out in the claims of different actors. For example, in a report which is less extensive and different in style from that of the CICA, the Institute of Chartered Accountants in England and Wales (ICAEW, 1992) addresses the question of the competence of the financial auditor in the environmental area. As in the case of financial audits where auditors will not always possess the full range of competences deemed necessary, “the skills necessary to conduct environmental audits.. include auditing (in this case environmental auditing), management, environmental and scientific expertise” (ICAEW, 1992, p. 112). The ICAEW argues that it will be necessary to rely on other specialists, whose competence can be gauged by appropriate qualifications with a reputable professional institute. In other words, from the point of view of the financial auditor, applied scientific expertise must be validated by reference to professional qualifications, just as it is for any other specialist, in order to be credible in the reliance process. The ICAEW task force has argued that accountants have a track record of expertise in this subcontracting process since national and international guidance has existed for many years. The Institute of Internal Auditors (IhA, 1993) states boldly that “the criteria for professional competence of environmental auditors is that they should be well versed in scientific principles”. However, the reader is not told what such scientific principles are other than that they may not always be available, a knowledge deficit which can be overcome by training or by the use of consultants. In both these cases, a certain kind of admission of ignorance simultaneously normalises the subordination of the scientist who has the status of “other expert” to advise on specialist points, such as emission levels. Scientific knowledge is externalised and treated as reliable but it is also placed lower in the hierarchy of expertise. In contrast to more traditional concerns about the hegemony of science (scientism), the authority of science in the environmental con-

text is also the condition of its subordination. For example, in the context of verifying emissions data, the ICAEW (1992, p. 108) argues that, “it is more likely that a relevant physical scientist or engineer would be the appropriate person to provide such verification because of the technical and narrow focus of such disclosures”. Implicit in such a statement is the notion of the accountant as having a broad field of vision and using the “narrow” specialist for particular “technical” problems. As the ICAEW (1992, p. 106) puts it, “the environment is no different from other specialist areas such as property valuation or interpretation of legal agreements”. The environment is one “area” among others which can be integrated into an audit process which will involve “discussion with specialists” (ICAEW, 1992, p. 106); “it is clear that risks of misstatement arising from environmental problems are in many respects no different from many other financial statement risks” (ICAEW, 1992, p. 107). Here we see another example of how claims for the relevance of accountants in the environmental audit field are strengthened, perhaps unintentionally, by the vision of a more integrated relation with the financial audit. Forms of knowledge which may be uncertain in localised practical contexts acquire reliability as they become distant from their context of origin. As Collins (1985, p. 145) has put it, “distance lends enchantment” and nowhere is this more apparent than the practice of reliance on other specialists in audit work. But reliance upon other experts, whether scientists upon accountants or vice versa, is not simply a natural process arising from a division of multidisciplinary labour. It expresses specific and often competing hierarchical relations between different bodies of expertise. What is at stake here is the representation of “science” as “other expertise” within the field of accounting. In general, occupational groups competing for territory will require both a strategy to establish relevance (similarity) and a strategy to subordinate competing claims to relevance (difference). A particularly interesting example of this concerns the domain of evidence

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

collection and analysis, where one might traditionally think that applied scientists had a comparative advantage. However, Gray (1993, p. 175) suggests that accountants can contribute to “evidence collection and evaluation” in the context of life cycle analysis and in an interview a Big Six auditor indicated that scientists can be “very trusting” sometimes, a perception which allows the “professional scepticism” of the financial auditor to be promoted. Similarly, Gray and Collison (1991, p. 18) admit that an audit in the strict sense of the term cannot take place without standards against which verilication can take place, but equally they are sceptical of the authority of science: “science has much to offer in the field of environmental audit and management. It cannot provide all the answers” (Gray & Collison, 1991, p. 22). Finally, a crucial dimension of the subordination of scientific know-how to that of the accountant follows from the institutionalized emphasis on the role of environmental management systems and their presumed effectiveness (ICAEW, 1992, p. 112). The managerial turn in environmental regulation essentially displaces the environmental audit task from direct forms of verification of physical things e.g. emissions levels, to indirect verification of the systems to control such verification. Financial auditors may not be competent to verify the assertion that emission levels were x at such a place on such a day. However, it is possible for non-experts to verify that the system to verify emission levels in relation to target was working adequately. The external audit process is a form of “control of control” (Power, 1994). As one advocate has put it: internal auditors do not have to be experts in tbeJield under review; their skills and techniques act as a template that can be applied to diverse systems, issues and controls, while recognising the knits to auditor expertise and involvement (Wade, 1995, p. 30, emphasis added). This shows how the managerial turn, which emphasises systems, does not just make skills relevant which were hitherto excluded. It places these skills at a “higher” level in the control process and reinforces a “managerial element

141

in senior positions” (Armstrong, 1985, p. 134). Indeed, accountants become relevant and superordinate at the very point at which their work can be decoupled from an evidential base. The management system provides a buffer between auditing skiUs and applied scientific specialties with an evidential base anchored, presumably, in natural rather than bureaucratic realities. In the end, environmental audit is not an “exact science” (Sykes, 1993 p. 31) and it is on the basis of this indeterminacy that it can be constructed as a project amenable to the claims of accountants.

CONCLUSION Environmental audits originated in the private transactional context of North America as a basis for providing internal evidence of due diligence in environmental matters (Palmisano, 1989; Roussey, 1992). More recently there has been a shift away from these specific and private roots as environmental auditing has been co-opted into the province of quality management and has become coupled to broader regulatory programmes with the aim of providing “a feeling of comfort” (ICC, 1991, p. 10; Pentland, 1993). Whether the largely assumed benefits of environmental audit wiIl generate, like financial audit, social expectations in excess of those that are justified, only time will tell. At the time of writing it was not clear how many industrial firms would register under the EMAS scheme; to a large extent the market for environmental audits is still in its infancy. However, far from giving methodological difficulties, the fact that this market is still developing means that issues about the institutional credibility and settlement of environmental auditing expertise remain open. The strategies of closure adopted by different interest groups are still to a large extent visible in documents, journals and conferences. In this essay I have been concerned with the presentational strategies adopted, mainly but not exclusively in the UK, to represent accountants as relevant experts in the environmental

142

M. POWER

auditing field. It must be remembered that there is no “natural” case to be made for or against a role for accountants. Claims to expertise do not simply reflect a discrete body of knowledge, whether financial, engineering, chemical and so on. Rather, the field of environmental audit is one in which existing knowledges are both transferred and transformed, in which a new configuration of expertise is constructed by the realignment of a particular portfolio of competences. Hence, the categories of scientist, accountant and auditor have no independent stability outside the processes of negotiation in which they have a role. There is no essence of the practice, no ultimate definition, and “the meaning of tasks is derived, in part, from the social meaning of the occupational group to which the people who perform them belong” (Kirkham & Loft, 1993, p. 508). There are only competing representations seeking to promote similarity claims and to acquire institutional legitimacy and stability (Smith & Wynne, 1989). It has been argued that appeals to the “multidisciplinary” nature of environmental audit practice, which have become something of an orthodoxy, are problematic. On closer inspection such appeals reveal processes of negotiating the relevance and priority of different forms of expertise. Notwithstanding the pluralistic rhetoric of multidisciplinary work, interested groups, such as accountants and their representatives, superimpose their own systems of classification onto the environmental auditing field in the construction of orderly practice. In other words, environmental auditing is a contested domain in which various experts seek to establish similarity relations between what they currently do and what they might do. This requires that the environmental audit task is framed in such a way that an overlap can be made to appear obvious and “natural”. Douglas (1987) reminds us that systems of knowledge are the product of negotiated relations of similarity which become institutionalised. In this

sense expert conflict is a function of “differences in perspectives between different traditions of observation and explanation” (Owen, 1992) and the claims of accountants on the territory of environmental audit are characterised by a distinctive self-presentation of that expertise (Wynne, 1989, p. 46). These definitional games depend on the capacity to appeal specifically to the relevance of financial auditing competence (see, e.g. Brewer 8z Mills, 1994; Oest, 1994) and, more generally, to the established position of accountants, their “symbolic capital”, in the hierarchy of professional knowledge. I have attempted to set aside questions of whether the involvement of accountants is a good thing, despite a few critical reference points, in order to analyse the discursive strategies by which accounting know-how is promoted. The managerial turn in environmental regulation has provided the necessary conditions for any prima facie plausibility both for the relevance of accounting know-how and, crucially, its superordinate position in the hierarchy of knowledge. Accounting firms are powerful organisations who can be expected to “attempt to build their goals and procedures directly into society as institutional rules” (Meyer & Rowan, 1992, p. 30). However, in the field of environmental auditing it remains to be seen whether superordination claims can be anchored in institutional realities. The field of environmental auditing remains diverse, the possibility for complex forms of “accreditation arbitrage” for environmental auditors exist, the rhetoric of multidisciplinarity is well estab lished and, crucially perhaps, accountants are stiII far from being unanimous in their views. Furthermore, attempts to formulate principles for the environmental audit process in EMAS and BS7750 seem to exacerbate rather than settle questions of knowledge. All this means that the construction of relevant expertise in the environmental auditing field is an ongoing process.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT

REFERENCES AaIders, M. (1993). Regulation and incompany environmentai management in the Netherlands. Law and Policy, 75-94. Abbott, A. (1988). The system ofprofessions: an essay on the division of expert labour. Chicago: Chicago University Press. Ahngren, R. (1989). Environmental audit-a new idea in Swedish environmental work. In UNEP, Environmental Auditing, TechnicalReport Series No 2 (pp. 63-68). Paris: UNEP. Armstrong, P. (1985). Changing management control strategies: the role of competition between accounting and other organizational professions, Accounting, Organizations and Society, IO, 129-140. Ashmore, A. D., & Stone, P. (1993). The ecoaudit specialists register, paper presented at The Network for Environmental Management and Audit Workshop, St. Mary’s College, Twickenham, 30 September. Ayres, I., & Btaithwaite, J. (1992). Responsive regulation: transcending the deregulation debate. Oxford: Oxford University Press. Beck, U. (1992). Risk society: towards a new modernity. London: Sage. Blokdijk, J. H., & Drieenhuizen, F. (1992). The environment and the audit profession, European Accounting Review, 437-443. Boden, R., Humphrey, C., & Lewis, L. (1993). Living dangerously: environmental audits in British Local Authorities. Paper presented at the EIASMworkshop on Accountants in Europe, Brussels, December. Bourdieu, P. (1990). Codification. In In other words: essays towards a reflexive sociology (pp. 76-86). Cambridge: Polity Press. BP PLC (1993). New horizons. London: British Petroleum PLC. Bregman, E., &Jacobson, A. (1994). Environmental performance review: self-regulation in environmental law. In G. Teubner, L. Farmer & D. Murphy @is), Environmental law and ecological responsibility: the concept andpractice of ecological self+rganization (pp. 207-36). Chichester: John Wiley & Sons, Brewer, P. C., & MiIIs, T. Y. (1994). IS0 9000 standards: an emerging CPA service area. Journal of Accountancy, February, 63-67. BSI (1993). Drafl for public comment: draft britishstandard revision of BS 7750:--192 specifzcatfon for environmental management systems (DC 93/400220). Linford Wood, Milton Keynes: British Standards Institute Came, M. (1993). Environmental auditors registration and training: the need for accreditation from within the consultancy service industry. Paper presented at The Network for Environmental Management and Audit Workshop, St. Mary’s College, Twickenham, 30 September. CEC (1993). Council Regulation (EEC) No 1836/93 of 29th June 1993 aliowing voluntary participation by companies in the industrial sector in a Community EcoManagement and Audit Scheme, O<i&Journal, 10 June, L 168, Vol. 36. CEC DG XI/ UK DOE (1993). Research into the Development of Codes of practice for Accredited Environmental V&@?rs within the framework of the proposed Eco-management and Audit Regulation. Cambridge: Judge Institute of Management Studies, June. CEC DGXI (1995). General guidance document on criteria for the acffeditation of environmental vertpers, under regulation I836193 and on the verification and validation approach. Brussels: CEC DGKI, July. CICA (1992). Environmental auditing and the role of the accounting profession. Toronto: Canadian Institute of Chartered Accountants. CoBins, H. (1985). Changing order: replication and induction in scientificpractice. London: Sage. Coopers & Lybrand Deloitte (1990). Positive auditfor the environment. London: Coopers & Lybrand Deloitte. Coopers & Lybrand Deloitte (1991). Your business and the environment: a DW revfewfor companies. London: Coopers & Lybrartd DeIoitte/Busiuess in the Environment. Coopers & Lybrand (1994). The overload question-some solutions, Quarterly Accounting Briefing, 3, 1-2. CowelI, E. (1989). EnvironmentaI audit in the BP Group. In UNEP, Environmental auditing, technical report series no 2. (pp. 32-49). Paris: UNEP. Dean, G. (1993). Standards of consuhancy for the public good-the perspective of the local authority. Paper presented at The Network for Environmental Management and Audit Workshop, St. Mary’s CoIIege, Twickenham, 30 September. Dennis, J. (1993). Contaminated land audits: practical aspects, Eco-Munugement and Audit, I, 22-26.

143

144

M. POWER Dewar, D. (1993). EnvironmentaI audit: the fourth E, Managerial AuditingJournal, 6, 7-13. DezaIay, Y. (1995). “Turf battles” or “class struggles”: the internationalization of the market for expertise in the “professional society”, Accounting, Organizations and Society, 20, 331-344. Douglas, M. (1987). How institutions think. London: Routledge. EIkington, J. (1990). The enofronmentul audit: a greenfilterfor companypolicies. Plants,processes and products. London: SustainabiIity/WorId Wildlife Fund. FEE (1993). EnvironmentaCaccounting and auditing: survey of current activities and developments. Brussels, Federation des Experts Comptables Europeens. Gale, R. (1995). The Canadian standards association’s approach to environmental auditing, Eco-Management and Auditing, 3, 36-40. Gambetta, D. (1994). Godfather’s gossip. Archive ofEuropean Sociology, 199-223. Grabosky, P. N. (1994). Green markets: environmental regulation by the private sector. Law and Policy, 419-48. Graham-Bryce, I. (1988). The approach to environmental auditing in the Royal Dutch/Shell Group of companies. In UNEP, Industry and environment: environmental auditing (pp. 8-10). Paris: UNEP. Gray, R., Walters, D., Bebbington, & Thomson, 1. (1995). The greening of enterprise: an exploration of the (non) role of environmental accounting and environmental accountants in organizational change. CrfticulPerspectives on Accounting, 2 11-239. Gray, R., & CoIIison, D. (1991). The environmental audit: green gauge or whitewash? Managerial AuditingJournal, 4, 17-25. Gray, R. (1993). Accountingfor the environment. London: Paul Chapman Ltd. Grayson, L. (1992). Environmental auditing: a guide to best practice in the UK and Europe. Letchworth: British LIbraryfTechnicaI Communications Ltd. GunnIngham, N., & Prest, J. (1993). Environmental audit as a regulatory strategy: prospects and reform. Sydnq Law Review, 492-526. HaIIiday, S. (1993). Quality uncontrolled. Accountancy, September, 48-49. Hajer, M. (1994). “Verinnerlijking”: the limits to a positive management approach. In G. Teubner, L. Farmer, & D. Murphy (Eds) Environmental law and ecological responsibility:the concept undpructfce of ecological self-organization (pp. 167-184). Chichester: John Wiley & Sons. Hemming, C. (1993). The EC eco-management and audit regulation: experiences from the pilot exercise, Eco-Munagement and Auditing, 1, 3-6. Hi& N. (1993). Professional development of environmental audit practitioners. Paper presented at The Network for Environmental Management and Audit Workshop, St Mary’s College, Twickenham, 30 September. HiIIary, R. (1993). The eco-management and audit scheme: upructiculguide. Letchworth, UK: Technical Communications (PubIishIng) Ltd. Huizing, A., & Dekker, H. C. (1992). The environmental issue on the Dutch political market, Accounting, Otgunfzutfons and Society, 17, 427-448. Hunt, D. (1993). Registration of environmental auditors-the EARA scheme. East Kirby, Lines UK: Environmental Auditors Registration Association. ICAEW (1992). Business, accountancy and the environment: a policy and research agenda London: Institute of Chartered Accountants in England and Wales. ICAEW (1995). Financial reporting of environmental liabilities:a dfscussionpuper London: Institute of Chartered Accountants In England and Wales. ICC (1991). Effective environmental auditing. Paris: International Chamber of Commerce. IEA (1991). Environmental auditing standards related to the study and evaluation of environmental management systems. Alexandra, Virginia: Institute for Environmental Auditing. IFAC (1995). Dfscussion paper: the audit profession and the environment. New York: International Federation of Accountants. IL4 (1993). Professional briefing note 2, environmental audit. London: Institute of Internal Auditors. Jasanoff, S. (1987). Contested boundaries in policy relevant science. Social Studies in Science, 195-230. KPMG (1995). Principles or rules? In FinancialReporting Update (pp. l-2, February). London: KPMG. Kirkham, L. M., & Loft, A. (1993). Gender and the construction of the professional accountant, Accounting, Organizations and Society, 18, 507-508. Iasch, C. (1979). The culture of narcissism. New York: Warner Books. Ledgerwood, G., Street, E., & Therivel, R. (1994). Implementing an environmental audft. New York: Richard D. Irwin Inc.

ACCOUNTANTS AND ENVIRONMENTAL AUDIT Lovelock, M. (1993). Iandiiil auditing: beyond compliance-a brief review of auditing for waste management facilities, Eco-Management and Auditing, 1, 32-34. Meyer, J., & Rowan, B. (1992). Institutionalised organizations: formal structure as myth and ceremony. In J. Meyer, & W. Scott (Eds) Organizational environments: ritual and rationality (pp. 21-44). New York: Sage. NACCB (1995). NACCB environmental accreditation criteria. London: National Accreditation Council for Certifying Bodies. Oest, D. (1994). What opportunities do the international quality standards offer CPAs with manufacturing clients or employers?Journal ofAccountancy, February, 60-61. Oliver, K. (1989). Registering environmental assessors in California USA, EnvironmentalAuditor, I, 21-24. Orts, E. W. (1995). Reflexive environmentai law. Northwestern University Law Journal, 1227-1340. Ost, F. (1994). A game without rules: the ecological self-organization of firms. In G. Teubner, L. Farmer & D. Murphy @ds) Environmental law and ecological responsibility: the concept andpractice of ecological self+rganisation (pp. 337-362). Chichester: John Wiley & Sons. Owen, D. (Ed.) (1992). Green reporting: accounting and the challengeof the nineties. London: Chapman & Hali. Pahnisano, J. (1989). Environmental auditing: past, present and future, Environmental Auditor, I, 7-20. Pentiand, 8. T. (1993). Getting comfortable with the numbers: auditing and the microproduction of macro-order, Accounting, Organizations and Society, 18,605-620. Piaut, J. (1989). AiEed Signal Inc. Health, Safety and Environmental Surveiliance Programme. In UNEP Environmental Auditing. TechnicalReport Series No 2 (pp. 5-27) Paris: UNEP. Power, M. (1992). The politics of brand accounting in the United Kingdom. European Accounting Review, 39-68. Power, M. (1994). The audit explosion. London: Demos. Power, M. (1996). Making things auditable, Accounting, Organizations and Society, 21, 283-315. Power, M. (1997). The audit society: ritual of verification. Oxford: Oxford University Press. P&mar, F. (1990). Trends in environmental auditing, Environmental Law Reporter, 20, 10179-10183. Radcliffe, V., Cooper, D. J., & Robson, K. (1994). The management of professional enterprises and regulatory change: British accountancy and the Financial Services Act 1986, Accounting, Organizations and Society, 19,601-628. Riesel, D., & Zarin, M. (1991). Environmental action program model. Cardozo Law Review, 1296-1314. Robson, K., Wiiott, H., Cooper, D., & Puxty, T. (1994). The ideology of professional regulation and the markets for accounting labour: three episodes in the recent history of the UK accountancy profession, Accounting, Organizations and Society, 19, 527-553. Rose, N., & Mimer, P. (1992). Political power beyond the state: problematics of government. British Journal of Sociology, 173-205. Rousseau, M. (1988). France’s experience with self-monitoring to combat industrial pollution. In UNEP, Industry and Environment: Environmental Auditing (pp. 22-25), Vol. 11 No. 4. Paris: UNEP. Roussey, R. (1992). Auditing environmental liabilities, Auditing: A Journal of Practice and Theory, 1 I, 47-57. Royal Society (1992). Risk: analysis, perception and management. London: The Royal Society. Salter, J. R. (1992). Cotporate environmental responsibility: law andpractice. London: Butterworth. Sammaiisto, K. (1995). Quality auditors and environmental auditors: can these two roles be combined, Eco-Management and Auditing, 3, 57-64. Sanehi,A., & Waire, A. (1991). Audit to test green credentials. Financial Times, 8 August. Sikka, P., & Wilhnott, H. (1995). The power of “independence”: defending and extending the jurisdiction of accounting in the United Kingdom, Accounting, Organizations and Society, 20, 547-581. Simmons, P., & Wynne, B. (1992). Responsible care: trust, credibility and environmental management. In Fischer, K., & Schot, J. (Eds.) Environmental strategiesfor industry (pp. 201-226). Washington D.C., Island Press. Simmons, P., & Wynne, B. (1994). State, market and mutual regulation? SocioEconomic dimensions of the environmental regulation of business. Working paper, Centre for the Study of Environmental Change, Lancaster University, UK. Smith, R., & Wynne, 8. (Eds) (1989). Expert evidence: interpreting science in the law. Oxford: Oxford University Press. Specht, L. B., & Buhr, N. (1994). Environmental auditing: approaches of the US and Canadian professions, Journal of InternationalAccounting, Auditing and Taxation, 3, 115-133.

145

M. POWER

146

Stittle, J. (1992). A sound way to move into a greener world. Accountancy Age, December 10, 20. Sykes, S. (1993). Land audits: law and practice, Ec@Munagement and Auditing, I, 27-31. Syrrist, Per A. (1989). A systematic approach to environmental auditing in Norsk Hydra. In UNEP, Enuironmental Auditing, Technical Report Series No 2 (pp. 55-57). Paris, UNEP. Teubner, G., Farmer, L., & Murphy, D. (Eds) (1994). Environmental law and ecological responsibility the concept andpractice of ecological seffhganization. Chichester: John Wiley & Sons. Van Cleve, G. (1991). The changing intersection of environmental auditing, environmental law apd environmental policy. Cardozo Law Review, 1215-1240. Von Ropenack, A. (1993). Piloting the EC ecomanagement and audit scheme: the experience of BSB Recycling GmbH, Germany, EceManagement and Auditing, 1, 7-9. Veldhuizen, H. (1989). Notanda Inc’s environmental auditing programme. In UNEP, Environmental Auditing, Technical Report Series No 2 (pp. 80-89). Paris, UNEP. Wade, K. (1995). Internal environmental audits: the roles of the internal audit department, Eco-Munugement and Auditing, 3, 24-31. Welford, R. (1992). European environment, special supplement: the eco-audit scheme and the britisb standard on environmental management systems. Bradford: European Research Press Ltd. Wilhnott, H. (1986). Organizing the profession: a theoretical and historical examination of the develop ment of the major accountancy bodies in the UK, Accounting, Organizations and Society, 1 I, 555-580. Woolston, H. (1993). Environmental auditing: an introduction and practical guide. London: British Library. Wynne, B. (1989). Establishing the rules of laws: constructing expert authority. In R. Smith, & B. Wynne (Eds) Expert evidence: interpreting science in the law (pp. 23-55). Oxford: Oxford University Press. Zuber, G. R., 81 Berry, C. G. (1992). Assessing environmental risk.JoumuZ of Accountancy, March, 43.

APPENDIX Abbreviations used in the text BATNEEC BSI CICA CWEC DOE EIA EMAS EMS FEE FSR GAAP ICAEW ICC IFAC IL4 NACCB UKAS

Best Available Technology not Entailing Excessive Cost British Standards Institute Canadian Institute of Chartered Accountants Corporate Wide Environmental Care Department of Environment Environmental Auditors Registration Association Environmental Impact Assessment Environmental Management and Audit Scheme Environmental Management System Federation des Experts Comptable Europeens Danish Institute of State Authorised Accountants Generally Accepted Accounting Practice Institute of Chartered Accountants in England and Wales International Chamber of Commerce International Federation of Accountants Institute of Internal Auditors National Accreditation Council for Certification United Kingdom Accreditation Service