Environmental Sustainability Metrics

There is a lot of talk these days about environmental sustainability, global warming, carbon footprints and green house gas. An off shoot of all these “new” environmental issues is the desire to measure them through indices or metrics. In fact, a huge cottage industry has sprung up on developing, refining and re-defining these environmental indices and metrics. If you Google “environmental sustainability index”, you will get over 472,000 web pages! Googling the term “environmental metric” will get you 138,000 pages. Each set of “new” metrics comes with a new glossary of environmental buzz words.

There is the Environmental Sustainability Index of 2005 put out by the Yale Center for Environmental Law and Policy which ranked the United States 45 out 146 – behind Congo and Botswana. Finland was ranked #1 while North Korea was #146. The same group also issued the 2008 Environmental Performance Index (EPI) which ranked the United States at 39 out of 149 – behind Albania and Uruguay. This time Switzerland was ranked first and the last place went to Niger. It is rather curious that the Yale Center that published these rankings stated emphatically in its executive summary that “the EPI’s real value lies not in the numerical rankings but rather in careful analysis of the underlying data and performance metrics.” If that’s true, why publish the numerical rankings at all?

The EPI does have some intrinsic value in that it looks at the two fundamental aspects, namely, environmental health (impact on humans) and ecosystem vitality (impact on ecosystem and climate change). The term “aspects” leads us directly to ISO 14001 Environmental Management Systems. One of the key elements of ISO 14001 is the requirement to identify all the “significant environmental aspects” of an organization’s operation. The ISO 14001 standard defines an “environmental aspect” as an “element of an organization’s activities, products, or services that can interact with the environment.” The environmental aspects of a company’s operation can be used as practical indices or metrics for its environmental sustainability.

To identify the environmental aspects, you need to look at all the activities throughout your entire operation that could affect the environment – both positively and negatively. Focus on four areas: material usages, energy consumption, water usages and pollutant releases.

For material usages, look at how much raw material you purchase to make your products and how much of it actually ends up in the products that goes out your door to your customers. If a lot of it ends up as scrap or waste byproducts, you have a negative environmental aspect in that part of your operation. If you recycle a lot of your waste by-products, that would be a positive environmental aspect.

On energy consumption, track your kilowatt-hour usages and natural gas consumption. You can track it in terms of unit consumption per unit of goods produced.

On water usages, you should focus on conservation. For example, look at how much water is consumed per unit of production and how much waste water you generate. Pollutant releases include wastewater discharges, hazardous waste generation and air emissions. This is by far the easiest metric to track since most are regulated through environmental laws. Your performance can be easily monitored through your wastewater treatment plant permits, your air permits and hazardous wastes manifests. Every July 1 of each year, the government requires most industries to provide a full accounting of its emissions to the environment during the previous year under the Toxic Release Inventory (commonly referred to as Form R). The TRI is by no means a perfect metric but it does force industry to reconcile its environmental releases.

How do you go about quantifying these environmental aspects?

Many companies use a matrix that looks at the environmental impact from the standpoint of severity and frequency. You can assign a numerical value of 5 to an activity’s severity rating if its environmental impact is severe. If that activity occurs all the time, you also assign it a value of 5 for frequency. The “overall” environmental risk would be 25 (the product of severity and frequency).

For example, if you emit a hazardous air pollutant through your stack continuously, the overall environmental impact of that emission would have a risk value of 25. In general, if you have an activity that is regulated by law or if it impact human or public health, it should carry a high severity rating. Once you go through all the activities within your operation and have assigned an overall environmental risk to each one, you will have either a table or chart showing you which specific activities you should focus on to reduce your environmental risk.

The best way to do this is to involve your line supervisors and have them go through the process of identifying these environmental aspects. Ownership is the key to success in this endeavor. The more people involved in the process, the more ownership your employees will have and you will end up with a more complete and accurate picture of your environmental aspects. An effective EMS always requires bottom-up involvement in addition to top-down support.

One final note of observation on reducing water consumption at a manufacturing plant: I once worked for a multi-national food processing conglomerate. One of its plants was consuming an inordinate amount of water as it performed its daily plant wash down. The cleanup crew was observed to be hosing every bit of food scrap down the drain with excessive amount of water. This lead to hydraulic overloading of its wastewater treatment plant. As it turned out, the factory had only one single water meter that measured the totally water consumption for the entire plant. The shift foremen had no idea how much water their staff was using on a monthly basis. I was able to convince the plant engineer to install individual water meters at various processing lines and to bill the shift supervisors directly for their actual water consumption. The water wastage dropped significantly as soon the supervisors saw their budgets being charged for actual consumption. Their staff began sweeping the food scrap off the floor before hosing it down. This was a clear case where a metric can be used to hold people accountable for undesirable environmental behavior.

The Practical Implementation of an EMS

On September 1, 1996, the International Organization for Standardization finalized its ISO 14001 EMS standards. They have since been updated in 2004. The term “iso” happens to be the Greek word for “equal”. These standards are designed to be “equal” globally. For example, a company in Singapore will have the same set of standards as one in Germany if they both adopt ISO 14001. 

 

It is important to keep in mind that ISO 14001 is not a legal requirement. It is a voluntary set of management standards that may improve your environmental performance. EPA encourages industries to adopt these standards but offers no specific incentives (such as reduced frequency of inspections) in return. Nonetheless, the benefits of ISO 14001 EMS standards are numerous. Many companies get ISO certification for business or marketing reasons. Simply put, they do it because their industrial customers require it. Others adopt the standards in order to improve their environmental performance. In either case, companies with an ISO 14001-like EMS are seeing many benefits, regardless of whether they get certified. For example, with an EMS in place, they find out that:

 

1. All their employees are now receiving consistent level of training.
2. Their employees are operating out of a common set of standard operating procedures.
3. The general public now has a better image of the organization.
4. Their environmental liability is reduced. 
5. Their waste management costs are now lower.
6. They now have a better overall environmental compliance record than before. 

The ISO 14001 EMS standards are in many ways a common sense approach to environmental management. It may surprise some of you that you already have many of the key elements of an EMS in place within your organization.

 

Here are some of the practical steps you can take to develop and implement an ISO 14001 EMS.

 

The first step you need to do is to secure the visible support of your senior management. An effective EMS must have top-down support that is visible to everyone in the company. You will also need a senior officer in the company to be the “environmental person in charge”. This person must have the confidence of senior management and has the authority to plan, enforce and maintain your EMS. This is also the person you go to get the resources you need to implement the EMS.

 

You then need to develop an Environmental Policy and have your CEO sign off on it. The Policy is the framework on which your EMS is based. In developing the policy, be realistic and do not over promise. And remember that your Environmental Policy represents your company’s vision to your employees and the rest of the world.  So you want to make sure you keep the promises made in the policy. Keep your environmental policy simple. Do not clutter it up with idealistic prognostications that sound good on paper but are hard to implement. The policy should clearly state the company’s commitment to continual improvement and pollution prevention as well as its commitment to comply with applicable environmental laws and regulations.

 

Once prepared, the policy must be clearly communicated to all employees and other interested third parties. To do that, you can post your environmental policy throughout the plant – similar to the way your safety policies are posted. You can also include the policy in your employee newsletter or post it on your intranet and company website.

 

The next step is planning. This is by far the most difficult step. You need to identify all the “significant environmental aspects” of your operation. ISO 14001 defined an “environmental aspect” as an “element of an organization’s activities, products, or services that can interact with the environment.” So you need to look at what you do throughout your company that affects the environment – both positively and negatively. Some examples of these environmental aspects would be air emissions, wastewater discharges, hazardous waste generation, heart generation, consumption of raw materials, and recycling of waste products.

 

The best way to do this is to involve your line supervisors and have them go through the process of identifying these environmental aspects. The more people involved in the process, the more ownership your employees have. An effective EMS also requires bottom-up involvement in addition to top-down support.

 

The term “significant” is not defined in the ISO 14001 standard. So it is up to your team to determine what is significant and what is not. Do not get hung up on an endless legalistic argument over this term. A general rule of thumb is to consider both the severity and frequency of the impact resulting from a specific aspect. Other factors you should look at include the following: Is the activity regulated by law? Does it have the  potential to harm public health or the environment? Does it affect your neighbors and community?

 

As part of the planning step, you need to set up your company’s pollution prevention goal. For example: Do you plan to reduce your hazardous waste generation by 5% or 10% each year? Whatever your goals may be, make sure they are realistic and implementable. And make sure you have the resources to meet the goal. If your goals are so high and lofty that your company fails to meet them during the first year, it may have a demoralizing effect on your employees. Take small steps instead. You can always set higher goals later. Remember that your EMS is a living document – a work in progress.

 

The next phase is implementation. Here you set out the procedures by which your company implements its planned goals and objectives. This is where the rubber meets the road. All your procedures must be clearly documented. Management of documents is an essential element of an EMS.  You need to have someone in charge of updating your procedures and ensuring that outdated procedures are removed from use. For example, you will need to set out procedures on how you stay current on environmental regulations that affect your operations. There is nothing more dangerous than using outdated regulations.

 

Records control is also paramount. Your EMS must ensure that your environmental records are accurately kept and easily accessible to those who need them. For example, all your hazardous waste manifests and related papers should be kept at one central location and one person should be responsible for getting the signed copy back from the disposal company.

 

Bear in mind that “documents” and “records” are not the same. Documents tell you what you need to do. Records are proof that your have done it. The difference between “documents” and “records” is that documents can be changed and records cannot. For example, your Standard Operating Procedures for running a wastewater treatment plant is a document. Your monthly Discharge Monitoring Reports that you are legally required to submit to the agency is your record.

 

Your implementation step will also include emergency planning and training of employees.  Prevention of chemical accidents should be a top priority in your EMS. The key here is to assign specific responsibilities to individuals for safe handling and storage of chemicals. Make sure that someone is responsible for checking the Material Safety and Data Sheet for safe storage conditions. Know what chemicals you have on hand and develop contingency plans to deal with them before you have a spill. These are all elements of an effective EMS.

 

In terms of training your employees, your EMS should identify who should receive what level of environmental training based on needs. Both the operator who generates and handles hazardous wastes and the clerk who fills out the hazardous waste manifests require training – but not at the same level of intensity. In other words, focus your training on significant environmental aspects. Your training requirements and procedures should be clearly spelled out in your documents. Evidence of training received will be contained in your training records. 

 

ISO 14001 is predicated on the continual improvement concept of Plan-Do-Check-Act. As stated earlier, this concept must be part of your policy. Now that you have planned and implemented an EMS, it is time to check it by performing an audit. The audit can be done internally (by your own staff) or externally (by outside auditors). Whichever way you go, you must ensure that you have the financial resources and management commitment to fix any problems you uncover in the audit in a timely fashion. This is particular critical if your audit uncovers some serious non-compliance legal issues. Failure to correct known violations quickly can and will be used against you in enforcement cases.

 

ISO standards require you to keep detailed records of all your audit results if you are planning on getting certified. That’s the price you pay for certification and all the benefits that come with it. If you are not interested in getting ISO 14000 certified, you may wish to forego the extensive audit reporting requirements. Your attorney will probably sleep a little bit better at night. Having an EMS in place without the certification will still get you many of the benefits. Regardless of whether you record your audit results, you should always do everything you can to fix any uncovered problems in a timely manner.

 

The last step in the continuous improvement cycle is for your senior management to review the status of your EMS and make improvements as needed. Your environmental officer in charge should play a lead role in this effort. It is recommended that you do a complete review of your EMS at least once a year.

 

EMS involves a lot of documentation. There is a company in Oregon that can help and guide you through the complicated document preparation process. If you decide to seek help, you should still be involved in the process. Remember – ownership is the key to success. People don’t wash their dirty rental cars before returning them to the rental car companies because they don’t own them.