10
IS0 1400 1 Registration: The Process, the Benefits, and the Choice of Registrar Chris navies and Phil Webber Thisarticle introduces the concept ofIS0 14001 registration,outlines related assessmentprocesses, and reviews the drivers behind developing an ISO- 14001-concordant environmental manage- ment system (EMS) and seeking third party registration of that EMS. It focuses on registration strategies for larger organizations and considerations in choosing a registral; including:auditor qualifications, standards for the conduct of EMS audits, and some issuesfor audit and registra- tion service providers. The authors conclude that it is beneficial to pursue an ISO-14001-concordant EMS and that the value ofthe system can be enhanced through registration. However,some thought should be given to choosing the appropriate registral;in particular to their EMS and audit approaches and to the qualifications of their audit team. Service providers are also cautioned to remember that IS0 14001 is not the same as IS0 9000, and that the registrar’s standard of care in the discharge of their work should reflect that. 01 998 John Wiley & Sons,Inc. The ISO 14000 series of standards is structured much like the IS0 9000 series, with its starting point in an environmen- tal policy. It has all the same marketing benefits as well, particularly for compa- nies attempting to develop markets inter- nationally. Environmental performance, like cost-competitiveness and product quality are critical to corporations. Envi- ronmental issues play a significant role in business decisions from plant expansion to product design. Companies that have received IS0 9000 registration have dem- onstrated reductions in operating costs, reductions in customer complaints, and an increased demand for their products and services. Based on the success of IS0 9000, the International Organization for Standard- ization (ISO) has developed a parallel series of standards for environmental man- agement, known as the IS0 14000 series. The goal of IS0 14000 is to protect human health and the natural environment through the application of systematic man- agement principles to environmental issues by business, industry, service orga- nizations, and government agencies. IS0 14000 defines the environment as the “sur- rounding in which an organization oper- ates, including air, water, land, natural resources, flora, fauna, humans and their inter-relation.” Within the IS0 14000 se- ries of standards, IS0 14001 outlines the following environmental management system (EMS) elements that must be ad- dressed in order for an organization to qualify for registration: environmental policy; planning processes which include the identification of environmental im- pacts and regulatory requirements, and the setting of objectives and targets; CCC 1088-1913/98/0802055-10 0 1998 John Wiley & Sons, Inc. ENVIRONMENTAL QUALITY MANAGEMENT / Winter 1998 / 55

ISO 14001 registration: The process, the benefits, and the choice of registrar

Embed Size (px)

Citation preview

IS0 1400 1 Registration: The Process, the Benefits, and the Choice of Registrar

Chris navies and Phil Webber

This article introduces the concept ofIS0 14001 registration, outlines related assessment processes, and reviews the drivers behind developing an ISO- 14001 -concordant environmental manage- ment system (EMS) and seeking third party registration of that EMS. I t focuses on registration strategies for larger organizations and considerations in choosing a registral; including: auditor qualifications, standards for the conduct of EMS audits, and some issues for audit and registra- tion service providers.

The authors conclude that it is beneficial to pursue an ISO-14001 -concordant EMS and that the value ofthe system can be enhanced through registration. However, some thought should be given to choosing the appropriate registral; in particular to their EMS and audit approaches and to the qualifications of their audit team. Service providers are also cautioned to remember that I S 0 14001 is not the same as I S 0 9000, and that the registrar’s standard of care in the discharge of their work should reflect that. 0 1 998 John Wiley & Sons, Inc.

T h e ISO 14000 series of standards is structured much like the IS0 9000 series, with its starting point in an environmen- tal policy. It has all the same marketing benefits as well, particularly for compa- nies attempting to develop markets inter- nationally. Environmental performance, like cost-competitiveness and product quality are critical to corporations. Envi- ronmental issues play a significant role in business decisions from plant expansion to product design. Companies that have received IS0 9000 registration have dem- onstrated reductions in operating costs, reductions in customer complaints, and an increased demand for their products and services.

Based on the success of IS0 9000, the International Organization for Standard- ization (ISO) has developed a parallel series of standards for environmental man- agement, known as the IS0 14000 series.

The goal of IS0 14000 is to protect human health and the natural environment through the application of systematic man- agement principles to environmental issues by business, industry, service orga- nizations, and government agencies. IS0 14000 defines the environment as the “sur- rounding in which an organization oper- ates, including air, water, land, natural resources, flora, fauna, humans and their inter-relation.” Within the IS0 14000 se- ries of standards, IS0 14001 outlines the following environmental management system (EMS) elements that must be ad- dressed in order for an organization to qualify for registration:

environmental policy; planning processes which include the identification of environmental im- pacts and regulatory requirements, and the setting of objectives and targets;

CCC 1088-1913/98/0802055-10 0 1998 John Wiley & Sons, Inc. ENVIRONMENTAL QUALITY MANAGEMENT / Winter 1998 / 55

Third-party registration involves the periodic audit of

an organization3 management system

by an independent third party.

implementation and operational ac- tivities, including designing a struc- ture and assigning responsibility, providing training, communication strategies, documentation of proce- dures, and emergency preparedness; checking and corrective action activi- ties such as the monitoring and measurement of results, audits, and preventative and corrective action plans; and management review of the system.

Similar to the IS0 9000 arena, the registration process under IS0 14001 in- volves an assessment (or audit) of an organization’s EMS by a registrar whose own management processes, the qualifica- tions of its personnel, and its audit proto- cols have been reviewed and certified by an accreditation body. An example would be where the Standards Council of Canada has accredited KPMG Quality Registrar to provide registration services to an organi- zation such as BC Hydro.

TYPES OF IS0 14001 AUDITS Self-Declaration

Originally, the IS0 envisioned self- declaration by an organization as a reason- ably expected outcome of successfully developing, establishing, and maintaining an ISO-14001-concordant EMS. Self-decla- ration only requires the periodic audit of an organization’s management system by an internal audit process (which may be resourced externally).

One example of where self-declaration may be used is with organizations such as the Canadian Electricity Association (CEA) which, through its Environmental Com- mitment and Responsibility Program, has outlined a requirement for their members to achieve conformance with IS0 14001. As an alternative to third-party registra- tion, CEA members are given an option for self-declaration of conformance to IS0 14001 as a means of meeting this require- ment, As more firms pursue third-party

registration, however, self-declaration may lose its credibility with external stakehold- ers, who will be left wondering if a com- pany has developed an EMS that meets the requirements of the st,andard, but not taken the last logical step.

Third-Party Registrations Third-party registration involves the

periodic audit of an organization’s manage- ment system by an independent third party. The objective of the registration pro- cess is to provide consistent registration of environmental management systems that meet the relevant standards in whatever industry wherever the organization oper- ates. The process ensures that the organi- zation may only be registered, continue to be registered, or be re-registered if its EMS is implemented, maintained, and meets the requirements of IS0 14001.

Third-party registration audits to IS0 14001 are classified as follows:

Multi-site: This term applies to an or- ganization consisting of one central and at least one satellite location. The environ- mental management system is controlled centrally with satellj te operations requir- ing the use of only a subset of the entire system. All sites must have implemented the system at the time of registration, with internal audit results available at the cen- tral location. Examplles may include:

a manufacturing concern with a cen- tral plant and one or more distribution points managed and run by the firm a central repair and overhaul facility operating service depots regionally where the satellite activity is limited to repair by replacement

For an IS0 14001 organization to qualify under this definition, the determi- nation of environmental aspects and certain other operational functions must be cen- trally managed, otherwise the organization will be defined as “blanket” or “single-site.”

56 / Winter 1998 / ENVIRONMENTAL QUALITY MANAGEMENT Chris Davies and Phil Webber

Blanket: This term applies to an orga- nization operating at more than one site, but providing essentially the same product or service from each location. The satellite operations vary only because of changes necessary for local regulatory requirements and slight variations in equipment. The

Registration Assessment PrOCeSS A registration assessment assumes that

an organization’s environmental manage- ment system is in place and fully opera- tional. In the registration assessment the team evaluates the organization’s compli- ance with the requirements of the standard

environmental management system is es- sentially unchanged at each location and may originate at the corporate level. At the time of initial registration, every site need not have implemented the environmental system. Sites can be assessed and added to the blanket registration as they are ready. Examples include:

a supplier of products deliverable to a larger assembly/design concern oper- ating plants in various locations, re- quiring the supplier to co-locate: a repair organization operating depots geographically, each possessing simi- lar capability and operating to the same standards; or a professional services firm operating offices in various geographic locations, each offering the same range of ser- vices delivered in a similar manner.

Single-site: This term applies to an or- ganization that operates from or deploys its personnel from a single location. Included in this definition are organizations that are affiliated, but whose operations are not the same from site to site. The environmental management system is developed and op- erated from the single location. Examples include:

a manufacturer with one facility pro- viding all product and after-market ser- vice; a repair depot that has one location to receive and repair product or dispatch repair personnel: or a professional organization with one location offering its services or from which it dispatches its professional staff.

0

by seeking evidence that:

There is commitment throughout the organization; Everyone is aware of the environmen- tal management system and how it affects them; The system is followed by those who are required to do so; and The system is used effectively to con- ti nu o u s 1 y improve environment a 1 performance.

The registration assessment involves a thorough review of all policies, proce- dures, work instructions, documentation, and internal audits. What follows is a de- tailed description of the steps in the regis- tration process.

Document Review Each registration assessment begins

with a document review. The review deter- mines if the documented environmental management system addresses all ele- ments of the IS0 14001 standard. Docu- mentation is a basic part of an environmen- tal management system. Nonconformance notes are generated if any inadequacies are found in the documentation. These must be corrected before the registration assess- ment.

Document review may be undertaken on- or off-site but, wherever possible, an on-site review is preferable as it allows the auditors to further assess the various risks associated with the particular audit and to ensure the risks are addressed during the registration assessment. Further, an on-site document review allows the auditee to explain their environmental system to the assessment team leader early in the

Each registration assessment begins with a document re view.

IS0 14001 Registration: The Process, the Benefits, and the Choice of Registrar ENVIRONMENTAL IlUALlTY MANAGEMENT / Winter 1998 / 57

During the registration

assessment, the auditors visit the

facility with a focus on the

implementation of the environmental

management system.

process. It also gives the assessor the op- portunity to see the organization first-hand and decide how best to plan the remaining assessment steps.

Registration Assessment During the registration assessment, the

auditors visit the facility with a focus on the implementation of the environmental management system. If the audit team dis- covers examples of noncompliance, they record and present them to the auditee for correction. When the audit team is satis- fied that the environmental management system has been effectively implemented and conforms to the standard, it will be registered and receive the registrar’s Cer- tificate of Registration.

Periodic Assessments Periodic assessments are used to

monitor the continued compliance of the environmental management system to the standard after registration has been achieved. These visits could also take into account the results of previous visits of the audit team, the results of internal audits, and the seriousness of any nonconfor- mance raised during the normal function- ing of the organization’s environmental management system. Regular periodic as- sessments tend to reinforce the principle of continuous improvement embodied by the IS0 14001 principles.

For each assessment visit, the registrar prepares a periodic assessment record documenting any nonconformances dis- covered, This report would be delivered at the closing meeting of the assessment.

REASONS FOR GETTING YOUR EMS REGISTERED UNDER IS0 14001

Why would an organization want to get its EMS registered under IS0 14001? (Note that the terms ‘registration’ and ‘cer- tification’ are used essentially interchange- ably,) From a business perspective, this is because the perceived benefits, financial and non-financial, outweigh the costs.

When looking at the benefits versus the costs, though, it is useful to distinguish between the developiment and implemen- tation of an EMS that is consistent with the requirements of the IS0 standard, and the act of pursuing and achieving registration itself. This is because the costs of each ac- tivity are clearly separable, even though some of the benefits may, in varying de- grees, be common to both.

Implementation Benefits: System enhancements of any kind in-

volve money and require the dedication of significant resources in terms of time and energy. However, it j.s generally accepted that the benefits of having a systematic approach to environmental management, and in particular one that meets the re- quirements of IS0 :14001, outweigh the costs. Some of the notable benefits include:

It has been showin that companies that practice effective environmental man- agement are usually superior eco- nomic performers and enjoy a lower cost of capital (sometimes through for- mal arrangements with lenders). Improvement in overall environment management, especially in terms of completeness of environmental im- pacts considered, alignment with policy, monitoring, checking and re- view activities, and systematic con- tinuous improvement of performance. Systematic application of checking and corrective actions (including mea- surement systems and related compli- ance and EMS auditing functions, cali- bration, nonconformance follow-up procedures, and formal management review) ensures continuous improve- ment of environmental, financial, and operational perflormance. Increased confidence and credibility for staff and middle management in the dis- charge of their environmental responsi- bilities improve dealing with senior management andl external parties.

58 / Winter 1998 / ENVIRONMENTAL QUALITY MANAGEMENT Chris Oavies and Phil Webber

Senior management enjoys more confidence in corporate governance regarding the environment; the corpo- ration can be more “transparent” in its operations, management, and report- ing. Reduction in actual or potential envi- ronmental incidents, particularly those that could be considered negli- gent: better demonstration of due dili- gence. In general, a systematic approach to environmental management will push along improvement in other areas and aspects of management.

Registration Benefits: Note that the benefits listed above are

achievable without registering your organization’s EMS under IS0 14001; how- ever, registration also has definable ben- efits, and the decision for most organiza- tions to pursue registration is a business one. These benefits can be generally cat- egorized between “meeting requirements” and “gaining competitive advantage. ” But consider that, even though the need for registration may appear to be imposed by the requirements of outside parties, in the end it is still really a question of continu- ing to have a license to operate or gaining a step on your competitors. Some of these benefits are:

The requirement for ongoing surveil- lance under IS0 14001 registration serves as a driver to ensure the imple- mentation and ongoing maintenance of the system, especially the “perma- nence” of the continuous improve- ment process-this is an area where most organizations fail after initial sys- tems implementation. Ensuring that the registrar will add value to the organization will provide it with more than a certificate to hang on the wall. The registrar should work to make you better at managing your environmental risks.

I S 0 14001 requirements are being driven up and down the value chain; in particular, customers are placing greater emphasis on the “greenness” of their suppliers, and are requiring sup- pliers to be IS0 14001 certified in more cases. The globalization of trade and com- merce means that organizations oper- ating in the international arena need the assurance provided by registration to an internationally recognized stan- dard. In the short run, proactively seeking out early registration is often a way to gain competitive advantage. Environmental issues and impacts af- fect everyone; the range of “interested parties” or stakeholders requiring reg- istration under IS0 14001 is increas- ing, and includes lenders, community interest groups, regulators, and share- holders. Where regulators and legislators want to move from enforcement of environ- mental regulation to more effective protection of the environment and en- courage organizations to move beyond compliance-driven EMS, IS0 14001 registration is increasingly being held out as an alternative-or at least a miti- gating consideration. Being registered is a way for corporations to avoid chan- neling resources into nonstop reactive response to regulator micromanage- ment of their operations.

Registration Strategy Often, an organization will begin to

develop its EMS with a test site, and will initiate the registration process the same way. For example, power utilities will of- ten implement and register an EMS at one of their generating operations. Once the implementation and registration are suc- cessful, they will use the lessons learned to implement an EMS at other sites in their operations. This strategy has many advan- tages, including refining the EMS for

IS0 14001 requirements are being driven up and down the value chain; in particular, customers are placing greater emphasis on the “greenness“ of their suppliers, and are requiring suppliers to be IS0 14001 certified in more cases.

IS0 14001 Registration: The Process, the Benefits, and the Choice of Registrar ENVIRONMENTAL QUALITY MANAGEMENT / Winter 1998 / 59

Organizations often find that it makes

sense to define the boundaries of the

registration to be the same as used those

to define their business units.

lessons learned through the development- registration process and identifying champions in an organization that can then provide assistance to others. As well, the organization will then be better positioned to determine if a “multi-site” or “blanket” is the more appropriate registration option for the rest of their operations.

Often, organizations that wish to de- crease the time required to register their facilities will combine the strategy of using a test facility with concurrent implemen- tation at other sites: they will implement areas of the EMS that are unlikely to re- quire modification, such as appropriate objectives and targets, standard operating procedures, and corrective and preventa- tive action programs. Once the EMS has been successfully implemented at the test site, they will then finalize the EMS at other sites.

While the most efficient long range registration strategy is often to use a multi- site registration, organizations often find that it makes sense to define the bound- aries of the registration to be the same as used those to define their business units. Organizations may find that business unit managers are more likely to take owner- ship for registrations that are completely within their areas of accountability. Fur- ther, registration of business units will not be delayed by any units that have not yet implemented their EMS.

Registration strategies will differ for organizations, depending on their size, complexity, timeline for registration, and the way boundaries are drawn around business units or operations. It is impor- tant to look at the strategy for registration early and to ensure that it is tailored to fit your organization’s needs and is expedient and cost-effective.

CONSIDERATIONS IN SELECTING A THIRD-PARTY IS0 14001 REGISTRAR’

One of the most critical steps in regis- tering your organization’s EMS under IS0 14001 is choosing the registrar. First, it is

important to recognize that all registrars are not the same. They can be quite differ- ent in:

Their approach to EMSs and to the reg- istration process (remember that IS0 14001 is not the same as the IS0 9000 series). How flexible are they in the in- terpretation and application of various elements of the standard? The way they structure their audit teams. For instance, do they use full- time auditors or will they be contract- ing out your registration? While a registrar would likely be able to reduce their costs through the use of subcon- tractors, you will need to address is- sues such as continuity of audit staff from audit to audit, the ability to con- tact all members of the audit team if you have questions, consistency of the audits performed by a registrar that uses contract auditors who may never have worked together, and the ability of a registrar to enforce confidentiality requirements and quality control with contract staff. Have they put together the right mix of inanagement system audit and technical environmental ex- pertise to suit your situation? What standards will be applied to the audit. Will they use the standards de- veloped by the Canadian Environmen- tal Auditing Association, or stick to the essential requirements of IS0 14010, 11, 12? Will their audit approach be risk driven and will it be tailored at all to reflect the uniqueness of your busi- ness or site? Their qualifications as a registrar (training, experience, resources, and which organization has accredited them as registrars:). Their recognition and acceptance- locally, nationally, globally. Are they recognized outside the “registration” community? Most importantly, what is their recognition and credibility with your key stakeholders?

60 / Winter 1998 / ENVIRONMENTAL QUALITY MANAGEMENT Chris Davies and Phil Webber

Providing additional value-added ser- vices such as industry-specific train- ing, benchmarking programs, and other assurance services, if they are able. For example, could they provide an audit report on the environmental performance data attached to your an- nual environmental report on informa- tion produced by the environmental management system. costs.

Second, your relationship with your registrar is usually long-term; conse- quently, you should use the same rigor in selecting a registrar that you would for any other significant supplier (especially in light of the first point). Third, given the differences in approach and philosophy that registrars may have, it is essential to establish who your registrar will be early in the registration effort (while the EMS is still under development, if possible), so that expectations are adequately delin- eated, issues addressed on a timely basis, and registration achieved when and as anticipated.

Checklist for Registrar Selection: (See Exhibit 1 for an example of a

registrar evaluation matrix paralleling this checklist.)

1. Qualifications Accreditation-if the registrar has the appropriate accreditation, organiza- tions can have confidence they are properly qualified and free of potential conflicts of interest. Accredited regis- trars will usually have their own qual- ity assurance system in place, will follow registration guidelines and re- quirements, and are evaluated against standard criteria. If a registrar is ac- credited, and an organization has dif- ficulties with them, then they can be reported to their accrediting body.

0 Industry experience-a registrar who knows the business in which the orga-

nization seeking registration is in- volved will have a much better time appreciating the nuances and special requirements of its EMS as it has been structured to meet the IS0 14001 stan- dard. Auditor/audit team qualifications- ensure that you meet and evaluate the people who will actually do your reg- istration assessment work, not just the marketing representative. Do they have the right training, knowledge and ex- perience? Does the team have the tech- nical expertise and balance needed for the assignment? Does the registrar have the resources as an organization to service a client of your size and re- quirements? It is important to note that the definition of acceptable work expe- rience may differ significantly between accreditation bodies. As well, the ac- creditation body for either the registrar or the auditor may have applied a “grandparenting” period where re- duced work experience a number of audit days were accepted.

Approachlphilosophy EMS approach-as mentioned above, all registrars are not the same. How do they view the relative importance of various elements of the standard and how far do they take the particu- lar circumstances of your industry and organization into account? Do they recognize that your EMS is your EMS? Registration approach-how do they handle some of the grayer aspects of registration, say for “multi-site” situa- tions or degree of implementation of audit activities? Are they timely in their feedback and follow-up work? Will they do the pre-assessment and documentation review work up front to help expedite matters? How will they handle any regulatory non-com- pliances they might encounter during their work?

IS0 14001 Registration: The Process, the Benefits, and the Choice of Registrar ENVIRONMENTAL QUALITY MANAGEMENT / Winter 1998 / 61

Potential conflicts of interest-are they doing consulting work in the EMS area, or are they affiliated with consult- ants, especially those who do work for competitors? Can their credibility be called into question for any reason (in- cluding too close of an association with the organization seeking registra- tion)?

3. Acceptance/recognition Stakeholder preference-do key stake- holders, especially those specifically requiring registration, recognize and have confidence in the registrar? . Accreditation and mutual recogni- tion-do other registrars and accredit- ing bodies recognize registrations performed by this registrar (especially in countries in which the organization operates, sells products or services, or that the organization’s customers sell their products or services)?

4. cost Cost elements will probably include: initial visit, EMS manual/documenta- tion review, pre-assessment audit, reg- istration assessment, partial or full re- assessment (if needed), surveillance audits, and associated expenses. Re- view the time allocated to audit the EMS. The time allocated to perform the assessment may vary significantly between registrars. Has adequate time been allowed to plan the audit and to address individual or unique signifi- cant environmental aspects?

QUALIFICATIONS OF A N AUDITOR Given that significant factors in choos-

ing a registrar (or even an EMS auditor in general) are the experience, ability, and compatibility of the auditors who will per- form the assessment of the EMS, what should one look for in evaluating them? First of all, an auditor must be qualified to perform his or her role in the audit. IS0 14012-1996 defines the qualification crite-

ria for environmental auditors. The quali- fications include:

Secondary educai.ion, or equivalent; 0 Work experience, including work

which contributes to the development of skills and undeirstanding in environ- mental sciences, environmental laws and regulations, management systems and standards, and/or audit proce- dures; Auditing experience in management systems; and

0 Formal training in the areas of knowl- edge listed above.

Auditors should maintain their com- petence and current knowledge of environ- mental management issues and auditing methods through a, program of work experience, formal training, professional development (journals, seminars, etc.), or on-the-job training. Auditors have to main- tain their status by conducting a minimum amount of audit activity over a three-year period.

There are a number of organizations that will provide auditor accreditations. Unfortunately, there is no international standard for environmental auditors as yet. While efforts are underway to de- velop an international standard for envi- ronmental auditor qualifications, there are a number of unresolved issues, such as experience requirements and the method by which i o evaluate auditor competence.

One way to help address this issue, from a client perspective, is to get refer- ences from the potential auditor, or pick companies from their experience list and follow up. Another key element to con- sider when choosing a registrar, especially if the organization is particularly con- cerned with the credibility or “quality” of the registration in the eyes of stakehold- ers, is the standard of care with which the registrar is going to perform the assess- ment.

62 / Winter 1998 / ENVIRONMENTAL QUALITY MANAGEMENT Chris Oavies and Phil Webber

Exhibit 1. Burrard Generating Station IS0 14001 Registrar Proposal Evaluation

Firm: Criteria: Value:

Qualifications: Credentials yeslno Resources 5 Registration Experience 10 Industry Experience 10 AuditTeam 10

Aooroach / Philosoohv: EMS Approach 8 Registration Approach a Service / Availability 9

Acceotance / Recognition: BCH / BGS Stakeholders 15 Accreditation recognition 10

Initial Registration 8 Ongoing 7

- cost:

Intangible - award up to 5

Total Score 100

ABC

GENERAL PRINCIPLES AND PRACTICE GUIDELINES FOR ENVIRONMENTAL AUDITING

One organization trying to address the issue of auditor certification and credibil- ity is the Canadian Environmental Audit- ing Association (CEAA), which is in the process of developing General Principles and Practice Guidelines for Environmental Auditing. The general principles and prac- tice guidelines are available on the CEAA website at http://www.mgmtl4k.com/ ceaa/index.html. These are expected to help ensure a greater degree of reliability, consistency, and credibility in environ- mental auditing. This in turn will enhance the value of audit services for users such as lenders, investors, regulators, business managers, and boards of directors in an evolving and expanding marketplace and will provide a level playing field for ser- vice providers.

With this endeavor, CEAA has tried to expand the depth and breadth of the guid- ance provided beyond that specified in the standards CANJCSA I S 0 14010, 14011,

A-One Star

and 14012 (which govern en- vironmental auditing and auditor qualifications). They have done this by moving to- ward the audit planning ap- proaches and standards of care (as two examples) ex- pected by established finan- cial and internal auditing bodies. However, the guide- lines have not reached the extent or degree of authorita- tive guidance such as that provided by the Canadian Institute of Chartered Ac- countants in their “CICA Handbook Recommenda- tions for the Provision of Assurance Services.” As well, in developing its prin- ciples and practices, the CEAA is still wrestling with

many issues of a legal nature regarding the provision of professional environmental auditing services.

ISSUES IN PROVIDING PROFESSIONAL SERVICE

On the other side of the coin, service providers-be they auditors or regis- trars-need to take note in their practice of the expectations that are developing in the industry for environmental auditors, and of the implication of the differences between the I S 0 9000 series and IS0 14001. For example, the number of “inter- ested parties” or stakeholders is far broader and their concerns are much more extensive. Also, one standard deals with product/process quality, the other with management of environmental impacts and, consequently, the related exposures and liabilities. These standards are more dissimilar than they are alike and for IS0 14001 auditors, the professional respon- sibilities and potential exposures may be much greater as we move down the imple- mentation road. Some items to consider for practitioners:

IS0 14001 Registration: The Process, the Benefits, and the Choice of Registrar ENVIRONMENTAL QUALITY MANAGEMENT Winter 1998 / 63

How will the standard of care in the execution of work be defined for envi- ronmental auditors? What are the ex- pectations, what will be the tests, and what bodies will be turned to for au- thoritative guidance? Due diligence by (and liability for neg- ligence of) practitioners of environ- mental auditing-how far will this extend? Will this mean that the qualifications and credentials of envi- ronmental auditors become more important? Ethics/professional practice stan- dards-how will these be defined and by who? Will practitioners be bound first by the standards and codes of con- duct of whatever profession they are already members (e.g., legal, account- ing, engineering) and then by the re- quirements of standard-setting bodies for environmental auditors, or vice versa? And what about disciplinary ac- tions-who will handle this responsi- bility and under what authority? Confidentiality of records-environ- mental audit findings and the related working papers could contain sensi- tive information. How can this be shielded from other parties when environmental auditors do not enjoy “client-attorney ” privilege?

Similarly, what about the relationship between auditors and the auditee’s lawyers if the audit requires inspection of documents held by the lawyer or as- surance that is dependent upon the rendering of a legal opinion? What pro- tocols for communication between lawyers and environmental auditors will need to be established?

CONCLUSION It is generally beneficial for organiza-

tions to develop and implement an ISO- 14001-concordant EMS. That the value of the system can be enhanced through third- party registration is also evident for most organizations, although each should do its own business case for registration indepen- dent of EMS development. A lot of thought must be given to choosing the appropriate registrar, in particular to their EMS and audit approaches and the qualifications of their audit team. Semice providers are also cautioned to remember that IS0 14001 is not the same as IS0 9000, and that the stan- dard of care in the discharge of their work should reflect this.

NOTE 1. This section is drawn rnainlyfrorn Chapter23, “Choosing

a Registrar,” in the IS0 141101 Implementation Guide: Cre- ating an Integrated Management System by Suzan L. Jackson, John Wiley & Sons, Inc., 1997.

Chris Davies, CA, CEA, is the director of environmental registration with KPMG Quality Registrar; Inc. He regularly reviews registration assessments and recommends organizations for registration, arid also performs IS0 14001 pre-assessment and registration audits. He is a lead instructor for the KPMG Quality Registrar, Inc, IS0 14001 Lead Auditor Course. He serves on the Board of the Canadian Environmental Auditing Association (CEAA), and is chair of their technical advisorygroup to develop general principles and practice guidelines for environmental auditing. Mr. Davies is also a member of Sub-committee 2 of IS0 TC207, which is charged with developing the IS0 14000 standards related to environmental auditing. Phil Webber; CA, works in the Power Supply group at BC Hydro, where he specializes in environmental-financial management. He is a member of the core EMS Project team, which is implementing an ISO- 14001 consistent EMS for the generation group. He has responsibility for registra- tion issues, EMS auditing, and many planning and performance measurement elements of the EMS. Phil is the chair of EMAR-BC, a regional association of environmental professionals dedicated to addressing social and environmental issues from a business, financial, and economic perspective. He is also a member of the Canadian Environmental Auditing Association and serves on their technical advisory group to develop principles and prac- tices for the audit of environmental management systems.

64 / Winter 1998 / ENVIRONMENTAL QUALITY MANAGEMENT Chris Davies and Phil Webber