Jean E. Shorett
Battelle, Pacific Northwest National
Laboratory
ABSTRACT
Environmental Management Systems (EMS) and the ISO 14001 EMS Standard have been widely discussed as ways to upgrade management of environmental activities at Federal facilities. Increasingly, there is recognition that the ISO Standard also serves as a general management tool. This broader view recognizes the value added in areas beyond what is usually seen as 'environmental.' This paper continues that expansion. It will outline ways in which an EMS can ease deployment of new environmental technologies. Although not currently recognized as such, an intelligently implemented EMS can become an important tool for reducing cycle time in technology deployment and enhancing ability to manage hurdles and impediments. In turn, streamlined deployment can support effective use of new technology in EM's Ten Year Plan and beyond.
INTRODUCTION
Environmental Management Systems (EMS) have been widely discussed as a way to upgrade management of environmental activities at Federal facilities. Initially, this focused on using the ISO 14001 Environmental Management Systems Standard (1) to address powerful forces for change facing Federal facilities. Examples within the Department of Energy (DOE) included: reducing the number of Headquarters directives while promoting sound environmental policy, managing diverse missions and regulatory requirements, dealing with rapid change, doing more with less, and promoting cost-effective environmental protection. (2) This was followed by fuller recognition of benefits to be gained from using a Standard-based approach in: institutionalizing pollution prevention, using performance indicators, amplifying related initiatives, and expanding the basis for discussions of regulatory innovation with regulators and stakeholders. (3,4) These issues are important in any decision to use an EMS approach. However, they represent what might be called 'the floor not the ceiling.'
EXPANDING VIEWS
Increasingly, ISO 14001 is also being recognized as a general management tool. That is, it can become a vehicle for achieving overall cost- and mission-effectiveness goals. This is an important change. A broader view more clearly recognizes the leverage provided. Environmental systems improvements are increasingly understood as enablers, adding returns in areas well beyond what is usually seen as environmental. Examples include: improved systems integration, better risk management, and supporting related management priorities such as performance-based contracting, integrated safety management, streamlining NEPA actions, or easing deployment of new environmental technology.
Using an EMS is a means not an end. Even in this expanded view, an EMS adds value by improving management structure and practices -- not driving policy. An EMS cannot balance risk with mortgage reduction, achieve equity among site end-states, or decide whether to ship waste across states. Neither can it guarantee budgets nor define what should be done first. In short, the ISO 14001 Standard cannot determine the 'what' of policy. However, it may be a useful tool for improving the 'how' by which policy is implemented.
In this same vein, an EMS cannot determine the optimal number of Focus Areas for environmental technology development or which technologies should be developed. It may, however, become a tool for effective deployment. Although not currently recognized as such, using the ISO 14001 Standard can aid in reducing cycle time for technology deployment and enhancing ability to manage impediments. In turn, streamlined deployment can enable more effective use of new technology in EM's Ten Year Plan and beyond.
ISO 14001 AND TECHNOLOGY DEPLOYMENT
The EM Ten Year Plan recognizes the need to rapidly deploy new environmental technologies as central to timely and cost-effective clean-up. Advances in science and technology are also key to addressing currently unsolvable technical problems. Yet no technical advance can be effective without being used. Across Federal sites, emerging technologies face a wide assortment of jurisdictional, regulatory, stakeholder, liability, informational, contractual, cost, budgetary, and site-specific hurdles. To make matters worse, there are substantial problems with inter-operability. Even technologies successfully implemented in one location must often start from scratch at another site -- or even across the same site.
Harnessing ISO 14001 in the service of technology deployment may sound odd to ears used to considering EMS in environmental terms, and science and technology in engineering terms. Particularly in terms of technology development, focus is often on scientific and engineering advances alone -- with little active consideration of deployment until the technical development is complete. Yet in practice, technology can also be seen as a tool (or series of tools) within an operating management system. How a new tool engages, enters, and fits within that on-going system can be central to its use and impact. More to the point, how entry of a new tool into its operating system is affected is certain to influence the speed and cost of implementation. In addition, it will also impact the speed, cost, and likelihood of the new tool achieving full deployment. Thus advances in technology can be seen as involving better science and engineering or better management systems -- and preferably both.
BASIC IMPROVEMENTS
A great deal of effort has gone into identifying primary and secondary barriers to commercialization, initial implementation, and full deployment of new environmental technologies. A Standard-based approach will not fix all of them. However, it may become a useful tool for easing the "unplugging" of an existing technology and the "plugging in" of a cheaper, faster, better one. As with other priorities, benefits from a Standard-based approach focus on addressing management challenges. These will necessarily reflect the missions, goals, and priorities of an organization. Having said that, almost any attempt to ease initial use of an new technology can benefit from four characteristics of an EMS: a more predictable environmental infrastructure, a systems approach and continuously improving management practices, and an externally-recognizable structure.
PREDICTABILITY
One central feature of a Standard-based approach is the creation of a common management framework. Sites, activities, and technologies can vary, but the management framework remains predictable. This is not to suggest structure for structure's sake or a regimented, one-size-fits-all program. Quite the contrary. In implementing the ISO Standard's basic elements (i.e., upper management commitment, identification of environmental aspects, setting goals and targets, etc.), sites, programs, or projects can develop approaches tailored to their needs and conditions -- but reflecting the Standard's common framework. That common framework may have profound effects at sites that are both physically and organizationally complex. A consistent framework can provide recognizable structure. This is what allows programs, projects, RPMs, and/or contractors to "plug in" to a larger infrastructure while retaining their identities. Especially at complex sites, a common set of organizational landmarks, language, and expectations for finding people and information can be important.
A more predictable environmental framework can speed results and lower costs by reducing uncertainty and clarifying needed decisions. Uncertainty -- and the nasty surprises that tend to go with it -- is almost always expensive. Thus a more predictable environmental management framework can aid technology developers in lowering transaction costs because tools can be developed with an understanding of the systems framework in which they will operate. At a minimum, this should allow developer/deployers to improve their "aim" in collecting now-predictable cost, performance, regulatory, and other needed information. Unto itself, this more predictable framework will not guarantee effortless permitting, regulatory acceptance, stakeholder endorsement, RPM and contractor enthusiasm, or commercial success. It can be expected to reduce surprises and 'bring-me-a-rock' episodes. In turn, this can make time to market more predictable and uncertainty easier to estimate, manage, and allocate -- useful features in getting managers with highly incentivized agreements to implement a new technology.
A predictable environmental framework can also help deploy successful technologies. This can be across one facility or from one to several others. That is, if a technology has been implemented at one location on a Standard-based facility, that experience with a predictable infrastructure should be generally transferable and available to ease use at other locations. This transfer should be available at other locations on the initial site or at one or more Standard-based facilities. Put simply, a Standard-based approach should reduce the need to re-invent the wheels of infrastructure each time a new technology is deployed. Starting from scratch for each new location should not be needed. In an era of declining budgets, the ability to rapidly diffuse successful innovations may be an important lever in confirming the value of public investment in science and technology. Thus a more predictable environmental framework may result in both strategic and tactical benefits.
SYSTEMS APPROACH
A key advantage of using the ISO Standard involves the effect that a systems approach can have on management practices. Early EMS benchmarking at DOE sites has shown that most, if not all, EMS elements are in place at most sites. The most frequently missing elements were a published environmental policy and integrated systems. That is, the elements for an EMS were already there -- but not necessarily linked or rolled out to the right people at the right times. Of additional concern, there were often multiple, unconnected renditions of otherwise useful EMS elements distributed across a site. In complex organizations, this is not surprising. However, these create uncertainties of interpretation to technology developer/deployers as well as general managers.
In an era of constrained budgets, compliance agreements, projectization, privatization, and similar initiatives, organizations without an integrated infrastructure are very likely to be inappropriately allocating support costs. That is, they are either paying too much for duplicate capabilities -- or subsidizing unknown and uncompensated levels of risk. Inflated support costs reflecting duplicate capabilities is easier to understand. However, the potential for overlooked and unmanaged risk to produce accidents, injuries, and unplanned releases may have greater strategic impacts. Not only can just one incident blow schedules, derail projects, and bankrupt companies but it can seriously undermine hard-won regulator and stakeholder confidence, and impede acceptance of new technologies for substantial periods of time. A well-managed EMS cannot guarantee safety, systems integration, or appropriate allocation of support costs. It can be a tool for reducing support costs, linking and leveraging systems, and managing risk.
EXTERNALLY RECOGNIZABLE
The third general advantage of using an ISO 14001-based approach is its status as an externally-recognized standard. This feature was recognized early as a way to build confidence. In short, it helps get technology developer/deployers out of the "trust us" business in environmental dealings with regulators, stakeholders, contractors, and Remediation Project Managers. Adopting an EMS will not instantly convince regulators to abandon inconvenient regulatory or permitting requirements. Neither will it insure full regulatory compliance. What it may be able to do is signal to both internal and external stakeholders that a change is underway.
Organizations using an intelligently-implemented EMS can expect to see lower levels of impact on environmental resources from their operations. This expectation is based on actions taken to implement EMS practices. Moreover, those improvements should be noticeable by stakeholders. It is these improvements in performance produced by a recognizable change in management approach that may open doors to improved dialogue with stakeholders.
This is especially important for technology developer/deployers since new technologies are -- by definition -- new. This requires interpretation and new technologies often straddle categories or fall outside definitions. This can require considerable negotiation. Few environmental statutes were crafted with federal facilities in mind. While perhaps understandable, this can result in situations where fundamental concerns for environmental protection in accepting new technology get mixed up with requirements adding little value. One hurdle in negotiations with regulators is that some site track records that do not inspire complete confidence. This can run up costs of compliance without improved protection. An externally recognizable EMS can show regulators and other stakeholders that things have changed. It can provide an externally-recognizable model against which facilities can demonstrate their management practices. This may enable regulators, stakeholders, contractors, and investors to re-calibrate their confidence in current (vs historic) management practices. It may also enable regulators to show that environmental protection is indeed being maintained if new technologies are shown flexibility on onerous but ineffective requirements.
CONCLUSION
In conclusion, it is important to note that elements of an ISO 14001 Standard-based approach that can ease technology deployment are some of the same ones that aid other management issues. Management priorities in a program or at a site will necessarily emphasize the missions, conditions and needs of that organization. However, a sampling of those issues was outlined above. Thus it is important to remember that adopting an EMS approach in the service of easing technology deployment also 'inherits' value-added in other areas. This can range from specifically environmental issues to management concerns such as program, site, and systems integration, risk management in performance-based contracting, streamlining NEPA actions or privatization. In each of these case, as with technology deployment, using the ISO 14001 will never be a 'silver bullet' but it may be an increasingly useful tool.
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