Environmental Management Systems – Necessary for every manufacturing facility?

I recently had a discussion about the need for environmental management systems to be required for every manufacturing facility. The following is my reply and I feel it is pertinent to not only manufacturing, but every organization. My current position as an OSHA compliance consultant that deals with a majority of dental practices and medical clinics has shown me that an EMS is also incredibly important for every area of our society. Think of the requirement to begin utilizing Pharmaceutical Waste containers to keep medications and anesthetic from getting into our water/soil tables. This is part of an EMS and has already begun to show promise in reducing the levels of medications saturating our water tables and getting into our food chain. While I focus on manufacturing facilities in this discussion, remember, environmental stewardship is part of everyone’s responsibility. We want to leave a cleaner planet for our kids and grand-kids, and this must start with us.


 

I do not believe that having a certified (ISO 14001) EMS is necessary for ALL manufacturing facilities. I do, however, believe that environmental impact must be at the forefront of every plant’s values. Certification is not a necessary aspect of creating and adhering to a culture of environmental stewardship, any organization can evaluate their potential impact on the surrounding ecology without needing international certification.

I am a strong proponent of large impact potential manufacturing facilities being required to comply with ISO 14001. Think of British Petroleum (it has been brought up in a previous post, but it is an excellent example) and the Deepwater Horizons oil rig disaster. Or the Texas City British Petroleum oil refinery explosions in 2005 and then again in 2015 (Collette M, Olsen, L & Malewitz, Jim (2015). Every time an incident occurs, there is always a “lessons learned” but many times it is swiftly forgotten. Is this an issue with the EMS or is it the organizational culture? I think that many times it is a combination of both, a large manufacturing facility implements a very thorough EMS, which then swiftly leads to a false sense of proactive compliance, which leads to complacency. My favorite saying from a safety manager I used to work with is “complacency will kill people, maybe not today, or tomorrow, or even next year. But it will end in death.” We can see this occur many times, specifically with the examples above.

I do not feel that every manufacturing plant requires and intense EMS, however, I do advocate for at least constant assessment of potential impaccts to the environemnt. This helps to reduce the cost of implementation, while reducing the potential negative outcomes associated with environmental disasters. Smaller facilities will never see an ROI with ISO 14001, but that does not mean that is the only EMS that can be adopted.

What I have found in my professional experience is that it is more important to build a culture of proactive safety and environmental stewardship versus focusing on just regulatory compliance. This can be a very difficult road to push through, especially when it comes to large manufacturing facilities. In these situations I firmly believe in very strict compliance with an almost heavy handed accountability program and much harsher punishments for ignoring environemtnal management compliance. I know that is not a particularly well received opinion, however many of the large facilities are only worried about the monatary bottom line versus the potential impact to life and nature. At times it is necessary to almost “force” compliance and follow this up with ways to increase proactive organizational culture.

We can see the success with this concept in OSHA’s VPP. As OSHA began to becvome much more heavy handed with their fines and inspections, they also provided the VPP as an incentive to increase a culture of proactive safety standards, not just compliance with a checklist.

The pros of an effective EMS is that it has the potential to increase international recognition and business, the environment will be less likely to suffer, and the surrounding area will not be subject to toxic waste runoffs. Of course there are some cons as well, it is very expensive, time consuming and difficult to become ISO compliant. The monetary ROI is almost non existent for many manufacturing facilities, especially smaller ones. It also has the potential of developing into a culture of complacency of strict enforcement is not maintained.

My final thoughts on this is that environmental stewardship should not be limited to just certified EMS programs. It can begin with us, the safety professionals, to lead and guide our organizations to understand and accept the fact that we all have a responsibility to protect our planet. While we may not see an immediate ROI, we will be able to hopefully, create a better future and cleaner planet for our children and grandchildren.

 

References

Kasim, A. (2015). Environmental management system (EMS). International Journal of        Contemporary Hospitality Management, 27(6), 1233-1253. doi:10.1108/IJCHM-01-2014-0045

Miler-Virc, A., & Glusica, Z. (2012). ENVIRONMENTAL MANAGEMENT SYSTEMS CERTIFICATION. Journal of Economic Development, Environment and People, 1(3), 22-31. Retrieved from http://search.proquest.com.ezproxy.libproxy.db.erau.edu/docview/1660472803?accountid=27203

Story by Mark Collette,  Lise Olsen and Jim Malewitz March 21, 2015, M. C. (2015, March 21). Texas City Lessons Discarded. Retrieved October 26, 2017, from http://www.houstonchronicle.com/texascity/

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