Environmental management systems

• ISO TC 207 SC1 WG3

With the increasing importance of environmental issues, environmental management systems (EMS) are becoming more and more commonly used by enterprises. This also considers SMEs that start to implement EMS as a result of their own decision or forced by the situation on the market e.g. their customers require it. That is why NORMAPME has nominated its expert Mr Arie de Graaf to represent SMEs in ISO TC 207 SC1 drafting on EMS standards.

ISO 14001:2004 is the most renowned standard in this field, but in its present format it is hard to follow by small businesses. It is aimed at large organisations with formal procedures and management structures. In order to make this standard more usable for SMEs the European Commission issued in 2004 a mandate to CEN for a guide on phased implementation of EMS.

Under the Vienna agreement CEN decided to delegate this task to ISO. The work on this guide, indexed as ISO 14005, has already taken more than 3 years provisioned for the publication of the document and the date of its publication has been postponed till 2010.

Throughout the drafting process NORMAPME was unsatisfied with presented drafts of the standard. It seems that the standard drafters were unable to write a document from SME perspective. As a result some of the participants became sceptic about the purpose of the entire project.

In June 9, a draft of the standard was proposed for balloting to become a final draft. Many comments (including NORMAPME's) pointed at the excessive complexity of the draft international standard (DIS), its lack of coherence and its general inadequacy to assist SMEs. The  European Commission's DG Environment contacted NORMAPME on this draft and NORMAPME advised DG Environment not to support the draft standard as it was not assessed to satisfy the objectives of the mandate.

Due to the volume and nature of the comments received, the participants opted for a re-drafting of the document. The new document DIS 14005.2 was made available for balloting to the participants of the TC from October 11th to December 8th, 2009. After consultation of its members, NORMAPME stated that it did not support the new DIS as it was still too complex and difficult to understand for SMEs (http://www.normapme.com/english/positions.htm). NORMAPME expressed the same position to DG Environment when consulted. The NORMAPME position was also sent to the secretariat of ISO TC 207/SC1/WG3.

However on the 11th of December 2009 the DIS 14005.2 was accepted for transmission to "final draft international standard" (FDIS) by a majority of national members. The FDIS will be circulated in the coming months to all national bodies for a 2 month vote. If the FDIS is not approved, the options of redrafting or publication as a Technical Specification will be open; as the current document is not adapted to the reality of SMEs NORMAPME will keep pushing for one of the latter solutions.

We therefore strongly encourage SME stakeholders to express themselves against the FDIS in their National Standardisation Organisations.

In parallel to the participation in the works of ISO TC 207, NORMAPME is involved in the creation of SME Task Group reporting to the chairman of TC 207. We hope that through this body we manage to make the standard writers aware of SME reality and to promote directly proposals relevant for small businesses.

For further information on this article please contact: Mr. Rémi Orth, r.orth@normapme.com or +32 2 282 0537

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• ISO TC 176 SC3 WG16

In relation to the standardisation work of ISO TC 207 NORMAPME has decided to follow the developments of ISO TC 176 SC 1 WG 16 working on of ISO 19011 Guidelines for auditing management systems. This guide standard considers not only EMS, but also QMS and other management systems.

It is important that auditing of management systems is adapted to the reality of SMEs and that small companies are not required to follow numerous formal procedures designed for large organisations. Thus, NORMAPME will try to include in the text special provisions addressing SMEs needs, so that these auditing guidelines could be relevant for all companies.

The first working draft of the standard was circulated for comments after the meeting in Paris in October. NORMAPME sent its comments but did not participate in the following meeting that took place in February in Tokyo. It seems that the current draft will be changed significantly as the group had to deal with 160 pages of comments. The second working draft should be distributed in the upcoming weeks.

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