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What is this EMS thing anyway?
What is this EMS thing anyway? On Campus
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nvironmental management systems (EMS) are a hot topic in higher education these days. Some government agencies look at them as some kind of panacea, through which they can reasonably expect an organization to meet all of its compliance obligations and be a better corporate citizen. Environmental health and safety experts on campuses, who often have genuine affection for sustainable outcomes, view them as anything from extra work with no extra benefit to the common thread that runs through all environmental issues on a campus. There’s no shortage of opinion, but let’s be clear about what these things are. An EMS with an ecological basis (‘‘true EMS’’) intends to involve the stakeholders of a company (its customers, employees, suppliers, shareholders, etc.) in a process by which the firm identifies, assesses, and reduces environmental impact, and evaluates progress periodically. What specific ecological impacts the firm studies is a matter left to the firm. This can be an organic or structured process, where the International Standards Organization (ISO) 14001 standard tends towards more structure. Nothing about this standard insists that regulatory compliance activities participate; though often firms do include them.1 The core of the true EMS is an organizational commitment to environmental protection, and the lifeblood of the true EMS is measurement of improvements—itself a very tricky process. When the EMS focuses exclusively on compliance activities, as opposed to environmental impacts of the firm’s choosing, it actually operates more like a ‘‘compliance assurance management system’’ or CAMS. The process is similar—the firm identifies areas for action, puts plans in place on a limited scale, checks effectiveness, makes corrections, then applies the fix to all similar activities in the firm. This process, used by both the true EMS and the CAMS, is called the Shewhart Cycle (also attributed to
Deming) of ‘‘plan-do-check-act.’’ The CAMS is simply a tool to be more certain (because absolute certainty is a myth) of the state of compliance efforts in an organization. It is a tool for internal use, because it requires no participation or accommodation by government. The core of the CAMS is an organizational commitment to regulatory compliance, which some would argue is not a substantial new responsibility. I differentiate these two systems because on a campus, ecological impact and regulatory compliance are very different things. Many people on a campus care about solid waste generation, recycling rates, organic food purchase, water and energy use, and so-called ‘‘green buildings.’’ Few people on a campus care about training records that help demonstrate compliance with government standards on this or that regulatory topic. We know that government generally agrees that laboratories generate a small – albeit exotic – portion of a nation’s hazardous waste, and most campuses have small sources of air and water pollution compared to utilities and manufacturing. Compliance isn’t appealing on campus, so, when there’s talk of a true EMS and the stakeholders aren’t talking about compliance, the campus health and safety manager had better gather his or her own resources to create the CAMS. The payoffs for these systems are as varied as the system structures themselves. A functioning true EMS is likely to reduce an organization’s environmental impact and reduce its operating costs. A functioning CAMS will probably better prepare an institution for inspection and reduce – but not eliminate – the possibility of a negative outcome. While none of these systems have guaranteed, ironclad results written into them, they each offer a different approach to the tricky problem of best managing a complicated and dynamic set of environmental and regulatory issues on campus.
1
With limited success. The National Database on EMS (NDEMS) found no correlation between existence of an EMS and improved compliance performance, when evaluating industrial firms with EMS in the latter half of the 1990s.
26
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
1074-9098/$30.00 doi:10.1016/j.chs.2004.09.004
E
nvironmental management systems (EMS) are a hot topic in higher education these days. Some government agencies look at them as some kind of panacea, through which they can reasonably expect an organization to meet all of its compliance obligations and be a better corporate citizen. Environmental health and safety experts on campuses, who often have genuine affection for sustainable outcomes, view them as anything from extra work with no extra benefit to the common thread that runs through all environmental issues on a campus. There’s no shortage of opinion, but let’s be clear about what these things are. An EMS with an ecological basis (‘‘true EMS’’) intends to involve the stakeholders of a company (its customers, employees, suppliers, shareholders, etc.) in a process by which the firm identifies, assesses, and reduces environmental impact, and evaluates progress periodically. What specific ecological impacts the firm studies is a matter left to the firm. This can be an organic or structured process, where the International Standards Organization (ISO) 14001 standard tends towards more structure. Nothing about this standard insists that regulatory compliance activities participate; though often firms do include them.1 The core of the true EMS is an organizational commitment to environmental protection, and the lifeblood of the true EMS is measurement of improvements—itself a very tricky process. When the EMS focuses exclusively on compliance activities, as opposed to environmental impacts of the firm’s choosing, it actually operates more like a ‘‘compliance assurance management system’’ or CAMS. The process is similar—the firm identifies areas for action, puts plans in place on a limited scale, checks effectiveness, makes corrections, then applies the fix to all similar activities in the firm. This process, used by both the true EMS and the CAMS, is called the Shewhart Cycle (also attributed to
Deming) of ‘‘plan-do-check-act.’’ The CAMS is simply a tool to be more certain (because absolute certainty is a myth) of the state of compliance efforts in an organization. It is a tool for internal use, because it requires no participation or accommodation by government. The core of the CAMS is an organizational commitment to regulatory compliance, which some would argue is not a substantial new responsibility. I differentiate these two systems because on a campus, ecological impact and regulatory compliance are very different things. Many people on a campus care about solid waste generation, recycling rates, organic food purchase, water and energy use, and so-called ‘‘green buildings.’’ Few people on a campus care about training records that help demonstrate compliance with government standards on this or that regulatory topic. We know that government generally agrees that laboratories generate a small – albeit exotic – portion of a nation’s hazardous waste, and most campuses have small sources of air and water pollution compared to utilities and manufacturing. Compliance isn’t appealing on campus, so, when there’s talk of a true EMS and the stakeholders aren’t talking about compliance, the campus health and safety manager had better gather his or her own resources to create the CAMS. The payoffs for these systems are as varied as the system structures themselves. A functioning true EMS is likely to reduce an organization’s environmental impact and reduce its operating costs. A functioning CAMS will probably better prepare an institution for inspection and reduce – but not eliminate – the possibility of a negative outcome. While none of these systems have guaranteed, ironclad results written into them, they each offer a different approach to the tricky problem of best managing a complicated and dynamic set of environmental and regulatory issues on campus.
1
With limited success. The National Database on EMS (NDEMS) found no correlation between existence of an EMS and improved compliance performance, when evaluating industrial firms with EMS in the latter half of the 1990s.
26
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
1074-9098/$30.00 doi:10.1016/j.chs.2004.09.004