Informational Companies with No SIGNIFICANT Environmental Aspects - ISO 14001

[Sidney Vianna]

An interesting article on the Environmental System Update magazine this month about the possiblity of small (service) organizations not identifying any SIGNIFICANT environmental aspects and still being certified to ISO 14001.

There is a request for interpretation to the TC 207 about this issue, but some people defend the position that if your environmental impact is minimal, e.g., a two men accounting firm. You could claim that the only E impacts are electricty consumption and solid waste (paper, trash, etc . . .). If this small organization has good energy reduction and paper recycle programs, one could make a case that their environmental impacts are really not significant.

But is significant a relative or absolute term in the context of ISO 14001? Obviouly the impact of the example above is negligible, compared to the ones resulting form a large steel mill or petrochemical plant.

One could also ask what is the point of a small organization implementing an EMS/ISO 14001?

But what say you? Would an EMS with no identified SIGNIFICANT aspect be compliant with ISO 14001?

 

[Randy]

This has the potential to be one of those killer topics Sidney...

There are more impacts, potential or otherwise, than the two specified.

There are impacts associated with these guys going to and from work; impacts of their service/product; impacts from the materials they use for turning out their product/service (not the waste end, but from the beginning of the life cycle of the material); and possibly others.

4.3.1 is pretty specific...."determine those which have or can have a significant impact..." Nowhere does it say."except when you ain't got none".

In a case like this the organization should redefine how it determines significance...move the bar down so to speak...

Is it possible? Probably

Is it likely? I'll put it this way....This is a duck that they will need to squeeze real hard to make quack.....

 

[Claes Gefvenberg]

One could also ask what is the point of a small organization implementing an EMS/ISO 14001?

But what say you? Would an EMS with no identified SIGNIFICANT aspect be compliant with ISO 14001?

Nooooope..... We are not supposed to compare our aspects with other organisations. What would that be in aid of when it comes to improving our own situation? Our aspects will not be any better off just because someone elses happen to be worse. See ISO14004, clause 4.2.2, step 4 of the Practical help table:

Step 4 – Evaluate significance of impacts The significance of each of the identified environmental impacts can be different for each organization. Quantification can aid judgement.

So be it if my most significant environmental aspect is an overflowing waste bin. We are supposed to consider what our own most significant aspects are, even if the neighbour happens to be a steel mill.

/Claes

 

[tomvehoski]

I've implemented ISO 14001 in a few small organizations without much in the way of environmental aspects/impacts. I agree you can always find some in any organization, but there is a point where you have to ask "what is the point". I worked with a robotics company where the biggest potential environmental issue would be spilling a quart of oil. I also had a small marketing company (designed print ads) being pushed by Ford to implement it (not sure if they ever did or not). I could not see a return on the investment of implementing the formal system, paying for an audit, and so on.

 

[Randy]

I've implemented ISO 14001 in a few small organizations without much in the way of environmental aspects/impacts. I agree you can always find some in any organization, but there is a point where you have to ask "what is the point". I worked with a robotics company where the biggest potential environmental issue would be spilling a quart of oil. I also had a small marketing company (designed print ads) being pushed by Ford to implement it (not sure if they ever did or not). I could not see a return on the investment of implementing the formal system, paying for an audit, and so on.

Did the organization explore any "positive" aspects? Did they look at the aspects of their "product"? Did they look at the aspects related to employees? Did they look at the aspects related to purchased material/services? Lots of things to explore here.....

If they were being pushed by Ford, they implemented, if not then they no longer supply Ford.

Most of the time ROI is keeping the customer as a customer.

 

[Wes Bucey]

Did the organization explore any "positive" aspects? Did they look at the aspects of their "product"? Did they look at the aspects related to employees? Did they look at the aspects related to purchased material/services? Lots of things to explore here.....

If they were being pushed by Ford, they implemented, if not then they no longer supply Ford.

Most of the time ROI is keeping the customer as a customer.

Sadly, my experience echoes this point of view.

The extortion tactics of some customers to require formal registration by their suppliers as a condition of doing business is absolutely deplorable.

Worse, the formal registration doesn't guarantee a better supplier, only a bitter one.

 

[tomvehoski]

We did look at both positive and negative, products, processes, suppliers, employees and so on. There was just nothing that could be improved to the point where I could really say "this will pay for itself" - other than keeping the customer. For example, since we had to have measurables, we counted the number of dumpsters of wood pallets that were taken for recycling. This had always been done, free by the company that took them. The only change for ISO 14001 was filling out a form to record it - I don't see much value there.

 

[db]

Let's look at my website business. I run it from home, and all environmenal aspects are minimial at best. Can say that I have no significant aspects. There are no programs that I can implement where the benefit would out weight the cost. So what am I supposed to do?

The key here is not whether there are any aspects, but any significant aspects. I say that a company can have no significant aspects. The question is can they become registered?

 

[RoxaneB]

Let's look at my website business. I run it from home, and all environmenal aspects are minimial at best. Can say that I have no significant aspects. There are no programs that I can implement where the benefit would out weight the cost. So what am I supposed to do?

The key here is not whether there are any aspects, but any significant aspects. I say that a company can have no significant aspects. The question is can they become registered?

I am by no means an ISO 14001 expert, so take this with a grain of salt...what does the Standard say in 4.3.1?

The organization shall establish and maintain (a) procedure(s) to identify the environmental aspects of its activites, products or servics that it can control over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment. ....

I read that to mean that there may not always been SEA's....especially if the significant impacts aren't so significant.

As long as, however, a process exists to identify such significance, I don't see why an organization without SEA's can not be registered to ISO 14001.

 

[Randy]

Pretty good toipc here

Using Rox's and db's line of thought we can expand it to any organization, doing anything, anywhere.

Let's think now along this line....

1) Organizations are required to identify the aspects of thier activities, products & services in order to determine those which have or can have a significant impact upon the environment...No question here..

2) In order to determine significance organizations must develop a consistantly utilized methodology based upon their own criteria, values, requirements, etc...

3) There is nothing prohibiting an organization from establishing a methodology that it consistantly uses that sets the significance bar so high that they never approach it.....getting theoretical here

4) Therefore an organization can meet the requirements of 4.3.1, not have any significant aspects (based upon its methodology for determination) and win their argument for registration....it's the organization and not the registrar that determines significance and the methodology......

This line of argument can create havoc because organizations with multiple/complex environmental issues can twist 4.3.1 and rightfully say.."nothing is significant".....

There may be other related issues though that could defeat this argument for registration when we look at other clauses of 14K