OPPORTUNITIES TO STRENGTHEN THE REGISTRATION AND ACCREDITATION SYSTEM FOR ISO 14001 CERTIFICATION

A comparison of ISO 14001 accreditation requirements and their influences on registrar practice and organizational environmental performance characteristics

Prepared By David Burdick PE

Executive Summary

This paper examines the following: 1) differences in accreditation requirements between the accreditation bodies of American National Standards Institute – Registrar Accreditation Board (ANSI-RAB) and the Dutch Council for Accreditation (Raad voor Accreditatie, i.e. RvA) regarding International Organizations for Standardization (ISO) 14001 certification process, 2) how these differences in accreditation requirements influence registrar practices, and 3) what inherent influences these differences ultimately appear to have on environmental performance of their client organizations.

A detailed clause by clause comparison of ANSI-RAB NAP (American National Standards Institute, Registrar Accreditation Board National Accreditation Program) E3.1 and E3.2, Europe’s EA-7/02 and International Accreditation Forum (IAF) Guidance to ISO 66 found significant difference in 12 areas of present and proposed accreditation requirements.

Nine registrars, responsible for over 40% of North and South American as well as world-wide ISO 14001 certification, participated in open ended surveys to explore if and how these differences in accreditation requirements corresponded to different registrar practices. (See Figures 4.1 and 4.2)

Organizations located in America and from the electronics industry were emphasized in the universe of registered facilities to be surveyed. From this universe, a random sample of three to four organizations from each of the nine participating registrars was selected for the open-ended survey format. (See figure 1.1) Thirty-one of thirty-four agreed to participate, giving a response rate of 94%. These organizations were surveyed regarding the following areas of concern:

  1. the significant impacts chosen,
  2. the methodology used to identify these significant impacts,
  3. the objectives chosen,
  4. the aggressiveness of targets set,
  5. whether the data was normalized or not,
  6. target attainment,
  7. the organizations’ interpretation of prevention of pollution,
  8. the organizations’ interpretation of continuous improvement,
  9. compliance to legal regulations.
  10. the value received from both the certification and the registrar itself

Responses for areas 1 through 9 were then rated against a generalized set of benchmark performance indicators reflecting industries’ best practices in reducing their most challenging environmental impacts. (see Figure 4.3)

70% of all US certified organizations are done so by European accredited or headquartered registrars. In order to better discern accreditation influences and national headquarters influences, the registrars and their organizations were classified into 3 different categories: Group 1 represents American based registrars with American (ANSI-RAB) accreditation and their client organizations, Group 2 represents American based registrars with European (RvA) accreditation and their client organizations, Group 3 represents European based registrars (with European (RvA) accreditation) but with American (ANSI-RAB) accreditation (in America) and their client organizations.

The study discovered and analyzed twelve major differences in accreditation requirements. It concludes that several of these differences are associated with significant registrar practices. For some of these differences in registrar practices, there appear to be associated differences in environmental performance indicators at the registered entities.

Note that this analysis is best viewed as a preliminary analysis and the observations should not be viewed as having statistical significance.

Nevertheless, the conclusions and observations should be valuable to those trying to understand and improve the inner workings of the accreditation and registration systems.

The following is a summary of these differences and their ramifications on registrar practice and organizational environmental performance characteristics.

Figure 1.1 – Overview of research

Figure 4.1 – Comparison of accredited registrar practices 1-7

Figure 4.2 – Comparison of accredited registrar practices  8-14

Figure 4.3 – Comparison of environmental performance
characteristics of accredited registered organizations

1. ROLE AND NATURE OF STAKEHOLDER ADVISORY COMMITTEES:

A balanced stake holder advisory committee may enhance system impartiality, creditability and ultimately the environmental performance of conforming entities. European and American accreditation bodies differ in the extent to which they require registrars to use balanced stakeholder advisory committees as a vehicle to ensure impartiality. RvA’s emphasis in particular on the use of such committees appears to have a significant positive impact on the actions of its accredited registrars. Some stakeholders may view a few of the differences as detailed later in this section as pushing the bounds of what is actually required by ISO 14001 and hence not realizable universally. Nevertheless, as a vehicle to achieve impartiality, it seems likely that the net result of increased use of empowered, balanced stakeholder advisory committees would also enhance the credibility and environmental performance of conforming entities.

2 SPECIFYING SCOPE OF REGISTRATION

The overall intent of an organization’s scope of registration is to capture within the environmental management system the environmental aspects of an organization’s activities, products and services that it “can control and over which it can be expected to have an influence.” (Fukuda 1999b). American accreditation requirements do not offer clear guidelines as to how to define scope of registration. This has lead to a wide variation in registrar’s definition as to what needs to be include under the scope of registration regarding production and research facilities, internal and corporate departments and level of supplier influence. Flexibility for individual entities to define the scope of registration may be appropriate and offer certain advantages, but it has the down side of reducing the credibility of the system as a whole.

3 CONTI NUAL IMPROVEMENT And PREVENTION OF POLLUTION

Continual improvement and prevention of pollution are areas where there exists a deep chasm between various ISO 14001 Technical Committee (TC) 207 national authors, particularly Europe and America. This difference spilled over when establishing specifications in ISO 14001.

European TC207 delegations generally wanted to measure environmental improvement in terms of reduced environmental impacts created, such as reduced toxic pollutants, energy used, etc. Similarly, European countries generally have regarded prevention of pollution as defined by EVABAT (Economically Viable Application of Best Available Technology), resulting in non-standard but constantly evolving implementation of newer pollution control technologies.

The American TC207 delegation argued that continual improvement should be measured with respect to enhancements in the performance of the system itself, such as how well internal audits capture non-conformities, improvements in management’s response to spills. Regarding prevention of pollution, although some forces in the US strongly argued for use of the pollution prevention hierarchy of reduce/recycle/reuse before implementing technological control solutions, this view did not carry the day within ISO 14001.

These differences in perspectives essentially prevented both European (EA-7/02) and ANSI-RAB (E3.1) accreditation bodies from aggressively addressing requirements to address the assessment of continual improvement or prevention of pollution. However, recent IAF Guidance to ISO 66 requirements have included language which supports registrars in taking a stand on systems that do not show evidence of the commitment to continual improvement or prevention of pollution. But it does not get into the issue of how progress should be measured.

Group 2 and 3 registrars appear to be close to implementing this recently established requirement, particularly regarding continual improvement.

Interestingly, the organizations certified by group 3 registrars, although not required to, were found to generally measure their own continual improvement in terms of reductions in adverse impacts as opposed to relying on system improvements to show continual improvement. Furthermore, these same entities generally choose to show commitment to prevention of pollution by focusing on the reduce/recycle/reuse protocol (i.e.-pollution prevention) rather than relying on end-of-pipe treatment, even though not required to do so the standard or by either American or European accreditation requirements. Critiques have asserted that such an approach should yield larger gains in environmental benefits than would a focus only on system improvement and end-of-pipe reduction.

American accreditation bodies should consider guidance that would call for a formal assessment of the mechanisms by which an organization intends to realize and measure their commitment to continual improvement and prevention of pollution. This suggestion is made even given the current absence of emphasis on substantive verses process improvements and a lack of emphasis on pollution prevention as compared the more broadly defined prevention of pollution.

4 LEGAL COMPLIANCE

Placing the results of an internal compliance under the protection of “Attorney-Client privilege” is a misapplied strategy sometimes used by American companies to avoid self-incriminating evidence being used against them in the event that a civil lawsuit was filed for violation of regulatory requirements. Unfortunately, this strategy also prevents registrars from viewing these audits in order to confirm the ISO 14001’s requirements regarding commitment to legal compliance are being realized.

Proposed American accreditation requirements have directly addressed this issue. They prohibit this practice, European requirements do not. As 70% of ISO 14001 registered organizations in the US are certified by a European based or accredited registrar, it would be desirable if European requirements addressed this issue more directly.

5 DETERMINING AUDIT DAYS FOR ASSESSMENT, RE-CERTIFICATION AND SURVEILLANCE

RvA has taken the lead in eliminating much of the variability caused by lack of a specific accreditation requirement by establishing a mandated minimum number of audit days for specific industry sectors and employee size. Registrars accredited by RvA (group 2 registrars) generally have procedures that quote a higher number of assessment days than Group 1 or 3 registrars do.

Without a consistent and minimum number of audit days and corresponding audit-day rate for specific industry sectors and employee count, registrars are forced into a competitive downward spiral, submitting bids with fewer and fewer audit days assured, spiraling down without any minimum floor.

This is a controversial area for registrars. Some who would like to think themselves above this, publicly denounce minimum audit day and rate requirements but privately agree that something needs to be done. Accreditation bodies stepping up to establish a level playing field would do much for strengthening ISO 14001 certification credibility and building stakeholder trust.

6 ENVIRONMENTAL COMPETENCY AND ONGOING JOB TRAINING

The competency of registrars and their auditors is a key component in accurately and fairly assessing an organization’s EMS. It is an important aspect in gaining stakeholder confidence in the integrity of the system and in assuring environmental improvement.

European accreditation requirements have a more detailed and specific set of requirements for auditor competency than do American accreditation requirements. European guidelines include specific requirements that the auditor team is environmentally competent in the specific industry sector regarding aspect and impact assessment, control and reduction techniques, and that the registrar itself has environmentally industry-sector competent system and people reviewing the contract and granting and withdrawing the certificate. However, no evidence could be found to verify that registrar practice follow these more specific requirements.

RvA uses a more rigorous means to verify auditor competency than ANSI-RAB, through its program that reviews the auditor education and experience and verifies the auditor’s competency through witnessed assessment. Evidence of registrar practice verified this requirement. However the requirement is slated to be discontinued due to its high cost and competitive pressures.

Thus, world-wide enhancement of the requirements for registrar and auditor competency would likely help to insure ISO 14001 certified organizations have a level, high quality playing field.

7 ASPECT AND IMPACT ASSESSMENT

The process of identifying and assessing environmental aspects and their impacts is an important corner stone of an effective EMS. Equally important is the criteria used to prioritize the significance of the identified aspects. Failure to either identify actual aspects or effectively assess and rank their significance can lead to an ineffective system. European accreditation requirements attempt to elucidate this area that is often not well understood. Overall, registrars with either European accreditation or headquarters had practices that indicated a higher sensitivity to aspect and impact assessment. Yet, evidence could not be found in all cases that the European accredited registrars were applying these more detailed European guidelines.

Organizations interviewed were rated on their accuracy of identifying aspects, impacts and significance relative to benchmark industry standards, and their aggressiveness in establishing objectives, targets and measurements to reduce them. Higher scores were achieved for organizations that are registered under either European accreditation requirements or have European headquarters. This raises the likelihood that European accreditation efforts to clarify this arena are being passed down from the registrars to the conforming organizations. American registrars could assist this process by adoption and enforcement of these European and IAF guidance. Likewise European accreditation bodies could provide increased confidence that organizations are consistent with these measures through establishment of a more vigorous means of verifying registrar practices in these areas.

8 COMPREHENSIVE INTERNAL AUDITS

The amount of knowledge gained from internal audits is in part a function of the training, thoroughness and knowledge of the internal auditors. European accreditation specifications, which list specific criteria for use in judging the comprehensiveness of internal audits, appear to increase the thoroughness with which registrars assess the effectiveness and comprehensiveness of an organization’s internal audits. Adoption of these requirements by the American accreditation body would probably likewise assist in encouraging more thorough and effective assessment of internal audits by registrars. This is likely to eventually lead to improvement in the client organization’s internal criteria for qualifying auditors and executing internal audits, and ultimately to improved the performance of the subject EMS generally.

9 RECORD OF COMMUNICATIONS WITH EXTERNAL INTERESTED PARTIES

In order to show evidence of conformity with ISO 14001 clause 4.2.d–specification on the commitment to compliance, as well as to ensure the ISO clause 4.3.3–requirement that the viewpoints of interested parties are considered when establishing objectives and targets, it is prudent for registrars to review communications from regulatory agencies and other interested parties, such as environmental advocacy groups. This has been addressed by ISO 66 and European accreditation bodies with a specific clause requiring registrar access to all records of communication. American accreditation guidelines do not require the same openness of records. Although there is a special clause added by the American accreditation body to ensure that compliance records are reviewable by the registrar, (Legal Compliance section 4), there is no similar statement requiring that all communication records pertinent to the EMS be reviewable by the registrar. This lack of mandate for complete disclosure of EMS appropriate records reduce the extent to which input from interested parties are utilized within the EMS audit and may lessen the audits’ effectiveness and credibility.

10 RE-CERTIFICATION OPTIONS–EFFECTIVENESS AND REASSESSMENT

To ensure that an organization’s EMS is periodically reviewed in totality, ISO 66, clause 5.6.1 stipulates that the registrar must carry out regular surveillance and re-assessment at sufficiently close intervals to verify that the organization’s EMS continues to comply with ISO 14001 and the registrar’s other requirements. Accreditation bodies have detailed the guidance on this requirement. European accreditation requirements differ in intent and detail from that of American accreditation requirements. European accreditation requirements emphasize that the effectiveness of the system should be verified and that the system should normally be fully reassessed after a period of 3 years. American accreditation requirements do not ask for registrars to assess the effectiveness of the organization’s system, and offer, as an option, bi-annual surveillances to replace a full reassessment of the system.

Despite the incentive to organizations to create verifiably effective EMSs by these European accreditation requirements, evidence could not be found that this European accreditation requirement was being thoroughly enforced within the surveyed registrars. Neither Group 1 nor Group 2 and only half of Group 3 registrars were found to have assessment practices that formally evaluated organizations for EMS effectiveness. Additionally, despite European accreditation requirements requiring full reassessment, all registrars generally follow American accreditation requirements that specifically allow for biannual audits. This however, was a benefit to organizations, as a significant number of organizations were found to highly value surveillance audits for their input into the EMS system.

Overall, guidelines that call for an assessment of the organization’s effectiveness (e.g., the European specifications), and for more frequent assessment (e.g., the American specifications) seems to represent superior approaches. In addition, the issue of registrar’s adherence to requirements appears to warrant more attention.

11 SAMPLING PLAN FOR A SINGLE CERTIFICATE COVERING MULTIPLE LOCATIONS

For marketing and economic purposes, some corporate organizations select to certify several sites under one certificate. ISO 66 does not specifically address this situation and thus it is up to individual accreditation bodies to form the rules that govern such a situation.

Accreditation bodies have developed different requirements. European accreditation bodies have listed several considerations a registrar needs to take into account when designing a sampling plan. Additionally the European accreditation requirements require that all sites be visited within a 3-year period, regardless of the number of sites. American accreditation guidelines stipulate specific requirements regarding the definition and sampling plan for multi-site certificates. However the sampling plan does not require all sites to be audited within a 3-year period if the corporation has more than 52 sites.

Regardless of accreditation requirements however, all registrars were found to follow the American accreditation requirements. This situation raises questions as to the adequacy of assessment for multi-sited certificates as well as the adequacy of European accreditation oversight of this requirement.

12 AUDIT METHODOLOGY REGARDING INTENT, ELEMENT PRIORITY AND STAGES

There are a variety of methods to assess an organization. Having an overall understanding of the intent of the audit helps all registrars ensure that the assessment achieves its purpose. Similarly, a common understanding of the more important elements of the standard helps registrars to prioritize non-conformances and keep findings in perspective. Finally, assessing the organization in two separate on-site assessments (commonly referred to as preliminary and certification assessments) has proven to be an effective means for registrars to assign the appropriate auditor(s) for the certification assessment of the facility, avoids the expenditure of client organization funds on assessment when they are not yet ready to undergo a full audit and averts inappropriate pressure to certify borderline facilities.

Other than requiring a two-stage audit, ISO 66 does not elaborate on the methodology of the audit. Accreditation bodies in Europe and America have chosen to clarify these requirements. There are significant differences however, between their approaches, particularly: 1) the intent of the second on-site registration audit, 2) which elements of ISO 14001 considered to be of highest priority, and 3) the location the first stage of the audit should be held.

This section of the survey concentrated on registrar practices regarding on-site assessment during the first stage of the audit.

Presently, American accreditation requirements do not require an on-site assessment during the first stage of the audit. It was found that the majority of Group 2 and 3 registrars require on-site stage 1 assessment, but the practice varied widely within group 1 registrars. This leads to a higher risk that: inappropriate auditors are assigned to the on-site audit, European accredited registrars would undergo a competitive disadvantage, organization’s waste financial resources due to the higher risk of failure and auditors are under increased pressure to certify borderline facilities.

PARTICIPANT OBSERVATIONS

The main aim of this research was to identify and discuss areas where differences in accreditation requirements might affect the level of reliance that can be placed upon registration of ISO 14001.

The numerous issues discussed in this paper clearly indicate that accreditation requirements do affect the level of reliance and the confidence that can be placed upon the assumption that registration to ISO 14001 will lead to improved environmental performance. Several ideas have been raised in discussion with accreditation bodies and registrars as to how to reduce these differences and increase the credibility and reliability of ISO 14001 certification. These ideas are presented here, not as recommendations, but rather to stimulate discussion.

Create A More Balanced Stakeholder Advisory Panel Within ANSI-RAB’s NAPC

Increase the role in ANSI-RAB advisory panel played by environmental departments within government, along with other stakeholder representatives of the general public. Representatives that have formed and maintained RAB’s accreditation requirements are not viewed as balanced between the various stakeholders affected by ISO 14001. This is seen as a main reason why EA-7/02 requirements have not been adopted

Harmonize Accreditation Requirements Worldwide

Strengthen the accreditation bodies concerted effort to harmonize accreditation requirements through IAF guidance. The efforts up to now, as have been shown, have not assured consistency. It has been suggested that accreditation bodies could open up the peer review process to more stakeholders than just other accreditation bodies. (Note: an accreditation peer review is an audit of one accreditation body by other accreditation bodies) This would serve to both gain the confidence of a broader base of stakeholders and influence the depth and direction in which the peer review is done, emphasizing a more thorough review of the assessed registrar’s practices in assessment days, auditor qualification, and continuous improvement assessment practices.

De-Link The System’s Financial Dependence

Reducing the financial link between the users and providers of accreditation and registration service is paramount to being able to maintain high accreditation requirements. The financial dependence between registrars, their clients and to some extent, their accreditation body is viewed as a force in weakening the environmental criteria within assessment protocol. Industry supports and finances certification and therefore appears to have access to and financial control over the system. Accreditation bodies earn their money through fees on the registration of an organization. Three ideas have been suggested in this area:

  • Establish an agreed upon charge per audit day and a minimum number of audit days per industry sector, employee count and other crucial variables. This will help reduce the competitive force which drives registrars to constantly reduce both the number of audit days per facility and the competence of their auditors
  • Form a pool of money for registrars who drop clients who have not effectively implemented ISO 14001 EMS. Payment would be equivalent to the general profit lost from dropping the client over a period of two years. This would reduce the incentive to keep clients for financial reasons that are not living up to the spirit within ISO 14001.
  • Create government and NGO funding to partially support accreditation bodies. This would serve to reduce financial dependence upon industry and potentially begin to represent environmental stakeholder interests.

About The Author: David Burdick

David Burdick is a Professional Engineer dedicated to quality and environmental management system assessment and implementation. His 15-year’s experience reflects a blend of international business acumen, manufacturing expertise and environmental and quality management. He has acquired practical knowledge and skills in: systems assessment, electrical manufacturing and assembly design, production packaging, food processing and automotive fabrication. He has been involved in registration practices for several years, including establishing an office in Japan for a European registrar, auditing in the US for a US registrar, and lecturing and training for ISO 14001. He is fluent in English and Danish.

This paper is a result of a two years study for the successful completion of a Masters of Science degree in Environmental Decision Making at the Open University, Milton Keynes, England.

Further Information

Copies of the entire 70 page paper, including detailed analysis of findings, or the complete 200 page thesis, “A comparison of American and European ISO 14001 accreditation requirements and their influences on registrar practices and environmental performance characteristics,” which include original anonymous research data can be purchased by contacting:

David Burdick
Sustainable Steps
4917 SE Aldercrest Rd.
Milwaukie, Oregon 97222
USA