Environmental management systems: How successful are they?

Environmental man-

agement systems

(EMSs) offer a set of

management tools

and principles that

can help integrate

environmental con-

cerns into daily busi-

ness practices. Such

systems have been in existence since the 1980s.

Many organizations have implemented some

type of EMS, presumably hoping to reap benefits

in the form of enhanced environmental compli-

ance and improved performance. Voluntary com-

pliance and reporting programs have also been

initiated on the federal and state levels in re-

sponse to promises made by proponents of envi-

ronmental management systems.

But have the promised benefits of environ-

mental management systems really materialized?

This article looks briefly at the results of some

current studies on the subject and offers a few

opinions from the field.

Some EMS Systems Currently in UseAn EMS is a set of management tools and

principles that is intended to help organiza-

tions integrate environmental issues into the

conduct of their daily business. An environ-

mental manage-

ment system is de-

signed to guide an

organization in al-

locating resources,

assigning responsi-

bilities, and con-

tinually evaluating

its practices, proce-

dures, and processes in order to enhance envi-

ronmental management.

Among the best known and most widely used

EMSs is the ISO 14001 standard, which is for-

mally entitled “Environmental Management Sys-

tems-Specification with Guidance for Use.” This

standard, which was developed through the In-

ternational Organization for Standardization

(ISO), was published in 1996.

Another important set of environmental

management principles are the Integrated Envi-

ronmental Management Systems (IEMS) guide-

lines developed through the U.S. Environmental

Protection Agency’s (EPA’s) Design for the Envi-

ronment (DfE) Program. These guidelines were

published in 2000, although the initiative actu-

ally began in 1992.

Environmental Quality Management / Spring 2005 / 25

© 2005 Wiley Periodicals, Inc.Published online in Wiley InterScience (www.interscience.wiley.com).DOI: 10.1002/tqem.20045

Kathleen Gibson

EnvironmentalManagement Systems:How Successful AreThey?

Does EMS implementation

enhance environmental

compliance?

Kathleen Gibson26 / Spring 2005 / Environmental Quality Management

One of the earlier attempts at formalizing en-

vironmental management concepts was the

chemical industry’s Responsible Care™ program,

which was first implemented in 1988. This pro-

gram was introduced by the American Chemistry

Council (ACC), then known as the Chemical

Manufacturers Association.

In addition to these systems, total quality

management (TQM) principles have been known

and used since the 1980s.

The EMS Promise

ISO 14001On June 4, 1996, shortly before publication of

the ISO 14001 stan-

dard, the U.S. House of

Representatives Sci-

ence Committee Sub-

committee on Tech-

nology held a hearing

regarding “The In-

creasing Importance of

International Stan-

dards to the U.S. Industrial Community and the

Impact of ISO 14000.”

Testifying at the hearing was Joseph Cascio,

chairman of the U.S. Technical Advisory Group

(USTAG) to ISO Technical Committee 207

(ISO/TC207), which developed and maintains

the ISO 14001 standard. Reflecting the opti-

mistic views of many EMS proponents, Cascio

(1996) stated:

ISO 14000 embodies a new approach to

environmental protection. In contrast to

the prevailing command-and-control

model, it challenges each organization to

take stock of its environmental aspects, es-

tablish its own objectives and targets,

commit itself to effective and reliable

processes and continual improvement,

and bring all employees and managers

into a system of shared and enlightened

awareness and personal responsibility for

the environmental performance of the or-

ganization. This new paradigm relies on

positive motivation and the desire to do

the right thing, rather than on punish-

ment of errors. Over the long term, it

promises to establish a solid base for reli-

able, consistent management of environ-

mental obligations.

Cascio went on to state, “ISO 14001 is a signifi-

cant and consequential development in our abil-

ity to protect and preserve the environmental re-

sources of our planet—transcending the

regulatory compliance approach—and must be

valued accordingly by both users and regulators.”

Cascio predicted that numerous benefits

would flow from implementation of the fledgling

standard. He stated:

ISO 14001 . . . provides a framework to di-

rect the use of organizational resources to

the full breadth of actual and potential en-

vironmental impacts through reliable

management processes and a base of edu-

cated and committed employees. Regula-

tory compliance is now a normal result of

this management strategy, along with

awareness, sensitivity, and preparedness,

greater reliability and consistency in meet-

ing environmental objectives, and greater

confidence in the organization’s ability to

prevent accidents.

DfE and Responsible Care™Other environmental management initiatives

have promised similar benefits. According to EPA,

the goal of the DfE Program is to create healthier

environments for workers, communities, and the

ecosystem. The Agency also states that DfE prin-

Cascio predicted that numerousbenefits would flow fromimplementation of the fledglingstandard.

Environmental Quality Management / Spring 2005 / 27Environmental Management Systems: How Successful Are They?

have implemented EMSs because major cus-

tomers have required them to. For example,

companies that supply the major automobile

manufacturers have had to implement environ-

mental management systems as a condition of

continuing to sell to carmakers.

Other companies have chosen to implement

ISO 14001 because they were impressed with

the results they achieved as a result of adopting

ISO 9000, the international quality manage-

ment standard.

Certain sectors (such as the chemical indus-

try) and certain multinational corporations saw

benefits in creating an

industry-wide or cor-

porate-wide EMS—not

the least of which was

an improved image

among both share-

holders and the gen-

eral public.

Study of S&P 500 Companies One study presented at a June 4, 2001, EPA

workshop entitled “Beyond Compliance: What

Motivates Environmental Behavior?” revealed

some expected results, as well as some surprises.

The study involved a sample of S&P 500 compa-

nies that had implemented some type of EMS.

The study suggested that firms facing higher

costs of complying with mandatory regulations,

higher potential liabilities, and “green” prefer-

ences from customers and investors are more

likely to exhibit a higher quality of environmen-

tal management.

In addition, the study determined that firms

with a higher level of pollution per unit of out-

put, and those that are more innovative, are more

likely to adopt a higher-quality environmental

management system.

Most interestingly, the study concluded that

the EMS incentives created by the threat of liabil-

ciples and approaches are useful in meeting regu-

latory requirements and elevating environmental

protection beyond mere compliance.

Similarly, Responsible Care™ is a voluntary

program that encourages chemical companies to

achieve improvements in environmental, health,

and safety performance beyond levels required by

federal laws and regulations.

According to the American Chemistry Coun-

cil, the program has resulted in significant reduc-

tions in pollutant releases to air, land, and water;

major improvements in workplace and commu-

nity safety; and the expansion of programs that

research and test chemicals for potential health

and environmental impacts.

Enhanced Regulatory Compliance?As these examples make clear, achievement

of enhanced regulatory compliance was touted

as one of the most compelling reasons for organ-

izations to implement environmental manage-

ment systems. Of course, the regulatory benefits

from adopting an EMS (in lowered fines and

other liabilities) are likely to be realized only if

firms go beyond mere formal adoption of the

system and actually demonstrate superior envi-

ronmental performance.

Have we, in fact, seen an increase in regula-

tory compliance among firms that have imple-

mented an EMS? The discussion below describes

some of the studies that have sought to answer

this question.

The discussion begins with an even more

basic issue: an exploration of which companies

are likely to implement EMSs in the first place.

Who Chooses to Implement an EMS?

A Range of Reasons to AdoptVery few studies have systematically analyzed

the motivating factors behind the decision to

implement an EMS. Clearly, some companies

Clearly, some companies haveimplemented EMSs because majorcustomers have required them to.


ity and mandatory regulations are not as strong

as those created by market pressures. The

strongest motivators for EMS implementation ap-

peared to be the high cost of offsite transfers of

toxic releases and public pressure brought to bear

on firms with high onsite toxic emissions per

unit of output (Khanna & Anton, 2001).

Regulatory Compliance among OrganizationsThat Implement EMSs

Ideally, enhanced regulatory compliance

should reflect the principles elaborated by

Joseph Cascio in the quote cited earlier: aware-

ness, sensitivity, preparedness, greater reliability

and consistency in

meeting environmen-

tal objectives, and an

improved ability to

prevent accidents.

Do facilities that

implement EMSs ac-

tually exhibit such

enhanced regulatory

compliance when

compared with non-EMS facilities?

Green Design Institute StudyA study addressing this issue was carried out

by researchers from the Green Design Institute at

Carnegie Mellon University (Matthews, 2004).

The research analyzed approximately 50 U.S. au-

tomobile assembly facilities. It found that facili-

ties that had implemented an EMS were not sig-

nificantly more compliant with environmental,

health, and safety regulations than were other fa-

cilities. In addition, the EMS-implementing facil-

ities had not shown greater reductions in pollu-

tants than had non-EMS facilities.

The Green Design study was based on ques-

tionnaires and a review of public data. The data

reviewed included the Toxics Release Inventory,

AirData, information collected under the Re-

source Conservation and Recovery Act, and the

Environmental Cost Handling Options and Solu-

tions (ECHOS) database.

Study of the Responsible Care™ Program Another study on compliance rates was pre-

sented at EPA’s 2001 “Beyond Compliance” work-

shop, discussed earlier. The study’s author evalu-

ated the American Chemistry Council’s

Responsible Care™ program.

His research concluded that the rate of envi-

ronmental progress in the entire chemical indus-

try had improved following the inception of Re-

sponsible Care™. However, the Responsible

Care™ firms themselves improved more slowly

over the same time period (King, 2001).

Lack of Conclusive Evidence on ImprovedCompliance

The studies do not conclusively indicate that

firms that implement an EMS have achieved a

better rate of regulatory compliance than firms

that have not implemented an environmental

management system. Nor do they show that

EMS-implementing firms themselves have be-

come more compliant since implementing the

management system—let alone moving to a stage

of “beyond compliance.”

So with the jury still out on whether imple-

menting an EMS actually enhances compliance,

it is unlikely that we can determine whether

there has been increased “awareness, sensitivity,

and preparedness,” “greater reliability and consis-

tency in meeting environmental objectives,” or

“greater confidence in the organization’s ability

to prevent accidents.”

Views from the FieldIn the course of writing this article, I infor-

mally polled a number of internal and external

auditors. In general, when asked “Does an EMS

help a corporation or individual location achieve

The studies do not conclusivelyindicate that firms that implementan EMS have achieved a better rateof regulatory compliance than firmsthat have not implemented anenvironmental management system.

Environmental Quality Management / Spring 2005 / 29Environmental Management Systems: How Successful Are They?

to get their place in order. Even if an out-

side consultant does most of the legwork,

the facility is still responsible for the day-

to-day compliance activities, and they see

firsthand what is required to maintain or

get a certification. Facility personnel also

learn more about managing the environ-

mental aspects of their facility.

Based on my own nearly 20 years’ experience

as an environmental auditor, I think that an EMS

is most effective when:

• it is implemented by the persons who are ul-

timately responsi-

ble for compliance;

• it includes incen-

tives for all the

stakeholders; and

• it is subjected to

regular continu-

ous improvement

review.

Have I seen increased compliance in facilities

that have implemented EMSs over those that

have not? Again, it depends. One thing is certain:

EMSs certainly make facilities and corporations

more “auditable,” which in this day and age is in-

herently a good thing.

ConclusionEMSs have been in existence in some form

since the 1980s. Recent years have witnessed an

increase in the number and sophistication of

EMSs. Among the systems in use currently are the

ISO 14001 standard, US EPA’s DfE guidelines, and

the ACC’s Responsible Care™ program for the

chemical industry.

Many organizations have implemented some

type of EMS, presumably hoping to reap benefits

in the form of enhanced environmental compli-

environmental compliance?” they all agree: It de-

pends. One auditor noted:

EMS implementation where environ-

mental requirements, policies, and per-

formance targets were integrated into

procedures, training, work planning sys-

tems, and other work-instruction sets in

operations, maintenance, and other

functional departments tends to im-

prove environmental results because

they influence the behavior of the peo-

ple who can make a difference to com-

pliance, releases, emission control, and

other environmental issues.

On the other hand, an EMS that re-

sides mostly in a set of binders in some

office, or in a data system that is separate

from a plant’s regular business informa-

tion, will tend to have little impact on

the facility’s day-to-day performance.

Operations and maintenance folk tend to

view these kinds of systems as someone

else’s problem, and have difficulty devel-

oping motivation to make needed behav-

ior changes.

One commentor wisely noted that the ISO

14001 standard’s focus on documentation and

paperwork provides a temptation to make ISO

systems turn into the “binder collection in some

office EMS” instead of the “EHS integrated into

daily operations EMS.” Based on that observa-

tion, it is less likely that an EMS implemented pri-

marily for the purpose of establishing ISO certifi-

cation will improve performance.

Another auditor noted:

ISO 14001 improves environmental per-

formance at the facility level because that

is where the compliance requirements are

most evident, and the facility is required

One thing is certain: EMSs certainlymake facilities and corporations

more “auditable,” which in this dayand age is inherently a good thing.


ance. Similarly, many in the compliance industry

believe that implementing an EMS can improve

an organization’s compliance.

Based on studies that have been done to date,

however, it is difficult to determine exactly what

benefits companies derive from EMS implemen-

tation, especially in terms of compliance.

Undoubtedly, additional research should be

done on the benefits of environmental manage-

ment systems. Until the benefits are clearly quan-

tified, it is difficult to see how audit policies and

voluntary compliance programs can be made

more attractive to the regulated community.

References Cascio, J. (1996). Testimony of Joseph Cascio, Chairman,

USTAG to ISO/TC207, Vice President, Global Environment &Technology Foundation, Hearing Before the House ScienceCommittee Subcommittee on Technology, June 4, 1996, on“The Increasing Importance of International Standards to theU.S. Industrial Community and the Impact of ISO 14000,”http://www.house.gov/science/cascio.htm

Khanna, M., & Anton, W. R. Q. (2001). Business-led environ-mental management: Regulatory and market-based incentives.In Beyond compliance: What motivates environmental behav-ior? US EPA R827919-01, http://es.epa.gov/ncer/publications/workshop/bynd_com_sess1.pdf

King, A. (2001). Voluntary environmental standards: Further-ing moral suasion while preventing moral hazard. In Beyondcompliance: What motivates environmental behavior? US EPAR827919-01, http://es.epa.gov/ncer/publications/workshop/bynd_com_sess1.pdf

Matthews, D. (2004). Environmental management systems:Informing organizational decisions. Presented at a conferenceentitled Corporate Environmental Behavior and the Effective-ness of Government Interventions, presented by US EPA’s Na-tional Center for Environmental Economics and NationalCenter for Environmental Research, April 26–27, 2004, Wash-ington, DC.

Kathleen Gibson is general manager of the Environmental Strategies Consulting LLC office in Somerset, New Jersey.

Environmental management systems: How successful are they?

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