Under the auspices of the ACC and the RAB, RC®-14001 is being tested at two pilot locations: BASF in Wyandotte, MI, and Arch Chemicals in Rochester, NY, where ENSR has been retained to provide technical consulting services. Both pilot test facilities intend to achieve registration to the RC®-14001 standard during 2002. The integrated management systems will be examined and certified by RAB-accredited ISO 14001 auditors who have been cross-trained in Responsible Care®.
Do We Need a New EMS?
Why do we need another environmental management system? We already have ISO 14001, the Europeans' Eco-Management and Audit Scheme (EMAS), British Standard (BS) 7750, the American Petroleum Institute's Safety and Environmental Management Program (SEMP, API Recommended Practice 75), the U.S. EPA Compliance-Based EMS, and the American Chemistry Council (ACC) Responsible Care® Management System. Beyond recognized programs, there are also hundreds of company-specific EMSs developed by corporations.
The ISO 14001 Juggernaut
The emergence of RC-14001 is best understood within the context of ISO 14001 and its extraordinary growth since 1996. To date, there are an estimated 36,000 ISO 14001 registrations worldwide. American environmental professionals often fail to appreciate the momentum of ISO 14001 because America lags the developed world in implementation of ISO 14001 with less than 5% of worldwide certifications. Just as when ISO 9000 (the standard for quality management systems) was first introduced in 1987, Europe and the Pacific Rim have eagerly adopted ISO 14001, out of the direct view of observers in the United States.
In Europe, the growth of ISO 14001 has begun to squeeze out competing EMSs. EMAS registrations have fallen far behind ISO 14001 registrations. In fact, a recent revision to EMAS embraces the verbatim text of ISO 14001 requirements, guaranteeing that all ISO 14001 certified European companies would satisfy the requirements of EMAS as well. The situation for BS 7750 is even more dismal - that standard was withdrawn in 1997 under competitive pressure from ISO 14001.
Despite its relatively slow start, U.S. ISO 14001 registrations are now surging, with the automotive, electronics, and chemical industries leading the field. At least four major drivers are responsible for this large wave of American ISO 14001 certifications:
1. Encouragement By Federal And State Regulatory Agencies - U.S. EPA Administrator Christine Todd Whitman recently issued guidance that the Agency looks favorably upon companies with EMSs. She has identified ISO 14001 as an EMS that produces reliable improvements in performance. In addition, Massachusetts, Texas, California, and Wisconsin and others have enacted or proposed environmental regulatory incentives for companies that have adopted EMSs such as ISO 14001.
2. Mandates From Automotive Manufacturers - Leading by example, Ford, General Motors, and DaimlerChrysler and Toyota have all insisted that their direct (Tier I) suppliers achieve ISO 14001 certification to continue to do business with them. Since purchased parts and materials account for over 60% of total vehicle value, suppliers are viewed as an extension of the auto manufacturer, which perceives that extended environmental leadership may be realized through the supply chain. Affected direct suppliers must be registered to ISO 14001 no later than the end of 2003.
3. Demands By Foreign Ownership - With the increasingly international character of businesses, more and more American plants find themselves under European or Pacific Rim ownership. Owners in those regions find ISO 14001 to be an effective vehicle for imposing uniform environmental management approaches across national boundaries. The foreign owners typically find ISO 14001 to be an effective tool for managing American environmental operations, which owners would otherwise view an incomprehensible tangle of regulatory-driven compliance initiatives with no ties to corporate norms.
4. Improved Bottom Line Performance - In addition to enhanced general awareness of environmental issues at all facility levels resulting in improved environmental performance, many organizations have realized substantial economic benefits from an ISO 14001 EMS. Companies such as Ford and Acushnet have reported annual savings in the millions of dollars due to continual improvement initiatives stemming from ISO 14001 EMSs. Moreover, firms registered to ISO 14001 are perceived by the business community as effective managers of environmental risk. Consequently, these companies may enjoy other financial benefits such as a lower cost of capital and a higher investor rating.
Isn't Responsible Care Enough?
Notwithstanding the increasing interest in ISO 14001, the American chemical industry has spent 15 years developing its own code of conduct, Responsible Care®. The rollout of Responsible Care® began 10 years before the advent of ISO 14001. Although Responsible Care® started as a program to avoid catastrophes like Bhopal, it gradually evolved and grew in scope. Over the years, it has expanded to encompass an imposing range of issues such as health and safety, product stewardship, and openness to the host community. By 1998, Responsible Care® even created an independent certification process of its own, known as Management Systems Verification (MSV).
Even the most ardent ISO 14001 supporter must admit that there is much to admire in Responsible Care®. With its expansive scope and noble aims, Responsible Care® inherently challenges its adherents more broadly and more ambitiously than ISO 14001. For example, ISO 14001 does not impose any health and safety requirements, leaves the extent of product stewardship up to the organization, and does not require communication of environmental performance to the host community.
Despite having accomplished so much with Responsible Care®, the chemical industry has found its proud achievement at risk. Customers, especially the automotive manufacturers, are insisting that the chemical companies adopt ISO 14001 or lose their business. These customers have essentially dismissed the recommendations of the chemical industry to consider Responsible Care® and the ancillary MSV process as the functional equivalent of ISO 14001 registration.
Customers have two chief objections. First, Responsible Care® is considered by some outside of the chemical industry to be a bundled collection of nebulous aspirations rather than a true management system in the classic 'Plan-Do-Check-Act' tradition. Second, skeptics question the rigor of the MSV process. The skeptics point out that MSV is primarily an informal assessment of a company's Responsible Care® program by other industry members and community representatives, who lack independence and accreditation by an authorized, recognized body.
The fate of Responsible Care® seemed uncertain. Would it be swept aside and withdrawn like BS 7750? Would it struggle along in the shadow of ISO 14001 like EMAS? Would the American chemical industry staunchly stand behind its commitment to Responsible Care® and refuse to acknowledge the popularity of ISO 14001 among a variety of stakeholders? Faced with growing customer demands and global interest in ISO 14001, the ACC produced a creative solution: synergize the best of ISO 14001 and Responsible Care® to formulate a technical specification (RC-14001) for third-party dual certification to both standards.
The Strength of Two Systems
The competition between the two systems notwithstanding, Responsible Care® and ISO 14001 have almost completely different strengths. ISO 14001 focuses narrowly on environmental management and emphasizes rigor in certification. Responsible Care® aims broadly, picking up health, safety, community, customers, and communication. Bringing the two standards together creates a rigorous, broad standard that can credibly yield outstanding performance.
Under RC®-14001, an organization can build a single environmental, health, and safety (EHS) management system that is simultaneously consistent with both standards, while providing customers and other stakeholders with a greater level of assurance about the company's operations. To aid firms interested in pursuing this new integrated standard, the ACC has created a RC®-14001 Management System Technical Specification, which systematically reconciles each element of ISO 14001 with the corresponding specifications of Responsible Care®, resolving each 'discrepancy' in favor of the stricter requirement. As a result, RC®-14001 offers several distinct features over ISO 14001 alone:
- An expanded aspect/impact assessment process
- Required proactive outreach to the host community
- Environmental performance reporting to stakeholders
- Required emphasis on upstream supplier issues and downstream customers
- Qualification, training, and review of contractors, transporters, and other service providers
Who Might Use RC® - 14001?
Chemical and allied industries with existing management systems are the most natural candidates for RC®-14001. Within that group, the businesses with the most hazardous chemicals are most likely to feel a sense of urgency in upgrading to RC® - 14001. By upgrading existing Responsible Care® programs to RC® - 14001, companies can add depth, rigor, and credibility. Conversely, by upgrading existing ISO 14001 EMSs to RC®-14001, organizations can add openness and breadth to their management system.
To provide comprehensive RC®-14001 support to the chemical industry, ENSR has teamed with Verrico Associates, LLC, a management systems and Responsible Care® consulting company headquartered in Newark, Delaware. Verrico Associates helped to develop the RC®-14001 audit protocol, and is currently the only ACC-approved trainer for RC®-14001. Together, the ENSR-Verrico team will monitor and help develop Responsible Care® certification programs, as well as provide up-to-date information and preparation services for the programs. ENSR and Verrico's RC®-14001 services include awareness training, internal auditor level training, gap analyses, and comprehensive implementation assistance.