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Will Green Tier Law be Repealed?

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A proposed Assembly Bill (AB 1059) would repeal the 20 year old Wisconsin Department of Natural Resources Green Tier program.  Although the bill is a long way from passage, the new law would likely eliminate the Green Tier program.  This article explores potential options Green Tier participants might consider if the Green Tier law is repealed.

The table below compares Green Tier with a few other popular alternatives for organizations wishing to communicate their superior environmental performance to others.  On the left, are the names of the programs including Green Tier.  The top row shows the characteristics of each of the program types.  A discussion of both the program types and the characteristics is below the table.

 Program Type Characteristics
Program TypePDCAAssuranceGlobalIntegrationMessage RecognitionCost to Implement
Green TierXStrong XMediumLow
Green Masters Some  MediumLow
ISO 14001XStrongXXHighMedium
EMASXStrong XMediumHigh
CSR NoneX MediumLow -Medium
CSR Verified StrongX HighHigh
Table showing comparison of Green Tier with other popular options.

Program Characteristics

PDCA – Plan Do Check Act continual improvement cycle? Most ISO type management systems are based on the PDCA model.

Assurance – Can the information be verified by an independent third party?

Global – Is this type of program globally recognized?

Integration – Does this program type integrate well with other protocols including ISO 9001, 45001 etc.?

Message Recognition – Are interested parties familiar with this type of program and messaging?

Cost – What is the cost to implement and operate this type of program?

Program types

Green Tier – A voluntary program modeled on the requirements of ISO 14001.   Green Tier was passed into law in April 16, 2004 to help Wisconsin businesses communicate their superior environmental performance to interested parties. Green Tier is based on the principles of continual improvement that help organizations continually improve performance in many different areas.  Green Tier also has an assurance component requiring participants perform periodic audits by an outside auditor of the organizations Environmental Management System (EMS).  A Green Tier EMS can be easily integrated with quality and occupational health and safety management systems into the organizations overall business management system.  Once accepted into the program, participants can communicate a strong message of superior environmental performance.  Participants have up to one year to implement their EMS making this a relatively low-cost investment to implement the management system.

Green Masters – The Green Master’s Program helps businesses focus on sustainability issues important to them while contributing to bottom line and top line growth. The program also provides a framework to develop, integrate, and grow sustainable practices. It also helps record and track progress in the sustainability action areas. Participants in the Green Master program declare that they meet criteria established by the program.  Green Master participants are recognized in four status levels.

Green Masters Levels

ISO 14001 – A globally recognized international standard based on the principles of continual improvement.  The International Accreditation Forum has established a robust accreditation and certification program that sends a strong message of superior environmental performance to interested parties.  ISO 14001 can also be easily integrated with other ISO management systems including ISO 9001 for quality management and ISO 45001 for Occupational Health and Safety Management Systems.

ISO 14001 Stabdard

Eco-Management and Audit Scheme (EMAS) – EMAS is very similar to the Green Tier program for organizations in the European Union countries.  It is a voluntary environmental management instrument, which was developed in 1993 by the European Commission. It incorporates ISO 14001 as a fundamental component and enables organizations to assess, manage and continuously improve their environmental performance. The scheme is globally applicable and open to all types of private and public organizations. In order to register with EMAS, organizations must meet the requirements of the EU EMAS-Regulation. Currently, more than 4,000 organizations and more than 12,700 sites are EMAS registered 

EMAS Logo

Corporate Sustainability Reporting (CSR) – Sustainability reporting has emerged as a cornerstone of corporate responsibility.  Reporting can  help businesses demonstrate their commitment to sustainable practices and transparency. The CSR trend is fueled by,  government regulations, heightened stakeholder scrutiny, and a growing recognition of the significance of ESG performance for long-term business success. There are several popular CSR reporting standards  each having their pros and cons.  Here is a list of some most recognized:

CSR reports are not based on a management system standard.  Instead, they are categories or areas of sustainability that the organizations report.  Organizations are not required to seek independent verification of the sustainability claims being made.  This has led to criticism by users of the reports that the information is not reliable and may be considered “greenwashing”.

IASSB and ISO 14019 Sustainability Assurance

Criticism of unverified CSR reporting has lead to development of new standards for verification of sustainability claims in CSR reports.  International Auditing and Assurance Standards Board (IAASB) has recently issued ISSA 5000 to help provide assurance to users of CSR information.   The International Organization for Standardization (ISO) is also developing ISO 14019 for sustainability information verification and validation (VV).  The ISO standards include a pathway for accreditation of VV bodies under ISO 17029.

Although Green Tier is unlikely to be repealed soon,  we hope this information gives Green Tier participants a broader picture of ways to communicate sustainability information to those interested in your performance.  For more information check out or Green Tier Services or you can contact us here or email us kalehner@envcompsys.com.

CorrectTrack 2.0 Release Soon

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Environmental Compliance Systems, Inc. (ECSI) is pleased to announce the release of CorrectTrack 2.0 soon.  CorrectTrack 2.0 marks a significant improvement in the applications ability to provide important ISO management system performance information quickly to users.

Over a decade ago ECSI began to explore digital tools to enhance our ISO consulting, auditing, and training practice.  We were looking for a cloud-based application that helps our clients and others implement and operate ISO continual improvement management systems.   Being unable to find a suitable off the shelf solution we began adapting available open-source bug tracking software.  The objective was to provide a systematic corrective action tracking process that was superior to existing Microsoft access database and excel spreadsheet solutions. The list of organizations using CorrectTrack has now grown to over 40 organizations and 450 individual users.  To our knowledge CorrectTrack continues to be the only cloud-based application designed exclusively for ISO 14001, 45001, and 9001 management systems.

CorrectTrack 2.0 has better dashboard user experience and more flexibility to let users configure it to their specific needs.  Users will have access to all the application features including:

  • Permissions based user access and functionality.
  • Approval gate process for corrective action investigation, verification, and closure
  • Risk management module for all ISO management system standards including 9001, 14001 and 45001.
  • Internal audit planning and follow-up.
CorrectTrack 2.0 Dashboard and Landing Page

As part of the CorrectTrack 2.0 rollout we are offering a free consultation to ISO management system experts and representative to explore how the application can benefit you ISO management system and improve your organizations occupational health and safety, environmental and even quality performance. 

Contact us for more information on how CorrectTrack 2.0 can help your organization’s ISO management system performance.  If you like what you see, we will help you get started with a free application trial period without any obligations or fees.

We are Presenting at Wisconsin Safety Council Safety 2022

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Join us at the conference. We are presenting on E-Tools for OHS Risk Management. Learn about how cloud based app and relational database are emerging as essential tools for EHS Managers. We will cover how to use these tools to:

  • Use a database to record the results of a JHA
  • Preform hazard risk reduction tasks
  • Perform audits of risk controls
  • Use e-tools to perform corrective actions
  • Communicate to leadership on EHS performance

Covid 19 Pandemic – How we Adapt

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Covid made us change how we work. Virtual meetings are the new normal when connecting with others and conducting business. Our certified training courses, internal and third party audits are conducted virtually with great results. A positive is dramatic reduction in effort and resources invested in travel to and from our clients or public courses. The negatives include more difficulty in performing audits on specific processes. Hand held devices do not show what is happening on the manufacturing floor well. They are also prone to loosing connection due to poor WiFi in some areas of the facility.

Contact us to learn more about how we are adapting and what we can do to help your organizations as it adapts to the new normal of Covid 19.

Kevin Lehner
President – ECSI
October 18, 2020

Our Thoughts on “Is ISO Registration the Answer?”

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A long-time professional college “The Honorable Scott Weyburn”, recently posted an interesting question focusing on benefits of ISO 9001 registration.  I posted a response that prompted Scott to ask for more so here it is.  Here is a link to Scott’s post which you might want to read first.

Understanding the Problem

The cause of the problem is easy to understand but difficult to correct. In my three decades performing nonfinancial audits for CBs if have found the CB customers primary interest is in sending a signal of sustainability to customers and other interested parties.  Improving sustainability performance is subordinate to that perceived imperative.  As a result, the organization focuses on passing the audit, not on having an effective management system.  Investment is in readying for the audit not on the resources of an effective system.  This is partially due to naivety and a lack of readiness in leadership in the organizations. 

It is also due to financial tension within the organization.  Investing in audit readiness only cost less than skillful implementation of an effective management system.  Leadership calculates “If all I want is certification for messaging and developing a MS with that goal is cheaper than an effective system, why would I invest in an effective system?”.  Leaderships misunderstanding is almost excusable considering the misrepresentation bombardment from CB’s and AB’s that their certifications and accreditation’s are evidence of system effectiveness.

Audit Services as Commodities

Another reason the certification process is failing is organizations seeking certification services perceive them as a commodity to be purchased from the lowest bidder.  They do not understand certification audits are a professional service where auditor and CB competence are critical to obtaining a return on their certification investment. 

To be competitive CB’s in the past would reduce the number of audits days and thereby reduce the cost of their service over their competitors.  IAF implemented MD-5 to try to control this audit day downward trend.  MD-5 is a complex system for determining audit days that was of some help early on.  However, as time went on CBs recognized that the only way to be competitive was to reduce the day rates for auditors.  Subsequently there has been a continuing downward spiral in compensation of qualified auditors, especially for contract auditors with no employment benefits. 

Many experienced auditors like myself have subsequently reduced the number of audits we perform for accredited CBs doing only enough to remain competent for purposes of certification.  The CBs now rely on inexperienced, inexpensive, and often incompetent auditors to perform audits on their behalf.

ABs Playing a Role

The ABs have also found themselves in a difficult financial conundrum.  There has been much consolidation in the CB business reducing the ABs revenue streams.    They recognize the threat to their clients, that major findings of auditor incompetence would bring, and are reluctant to issue meaningful nonconformities that compel change.  The incentives created by the ABs for CBs to improve their performance are more prescriptive and lead to “lipstick on a pig” corrective actions that exacerbate the problem.

Conclusion

These are tough problems to solve that cannot be wrestled to the ground overnight.  The financial assurance industry addressed similar problems with Sarbanes–Oxley Act of 2002 as well as in the Accounting Standards Codification issued by the Financial Accounting Standards Board (FASB).  The best chance of fixing the underlying problems with assurance in the non-financial sector is to enact similar legislation which is unlikely to happen in the foreseeable future.

ISO 45001 TC 283 – International Meeting Kigali, Rwanda

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The ISO 45001 Technical Committee TC 283 is meeting in Kigali, Rwanda the week of October 6-12, 2019.  The meeting will start with a plenary of all attendees to update national members on TC 283 developments.  Task Groups (TG) and Work Groups (WG) will meet independently to work out the contents of several new work items that in are in progress including:

  • TG1 – Communications
  • TG3 – Revision of the High Level Structure (Annex L Appendix 2 & 3)
  • WG2 – Psychological Health and Safety at the Workplace
  • WG3 – Implementation Handbook

The TG3 discussions on revision of the ISO High Level Structure will focus on issues that have been encountered by users of ISO 45001 with respect to:

  • The definition of risk as it applies to an OHSMS
  • The relationship between risk and opportunity and the traditional OH&S discipline specific terminology ‘Hazards and Risks’
  • Outsourced processes and how these to the OH&s discipline.

Comments are welcome here on opinions of changes to the HLS that will benefit the discipline specific ISO 45001.

ISO 14002 Results from Seoul, Korea September 2, 2016

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IMG_0406The ISO 14002 Ad Hoc Group completed its work on Wednesday, August 31 and I presented the output of the group work at the Committee Plenary with all participating countries on Friday September 2.  The purpose of the presentation was to help all participants understand what ISO 14002 is about.  The title of the standard is:

ISO/TC 207/SC1 Ad Hoc Group: ISO 14002:200x  – Guidelines for application of ISO 14001:2015 framework to environmental aspects and environmental conditions by topic areas.

The presentation was well received and the committee will now internationally ballot the ISO 14002 New Work Item Proposal (NWIP) in October of this year.  If the ballot is successful the development of these new guidelines will likely begin in early 2017 and will be discussed at the next ISO 14001 international meeting June 2017 in Halifax, NS.

ISO 45001:201X – Occupational Health and Safety Management

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Safety-BlogsThe development of ISO 45001 for Occupational Health and Safety Management Systems had a significant setback early this year.  By a narrow margin the international committee voted to refer it for additional review and comment.   ISO 45001 is being developed to replace OHSAS 18001:2007.

The effect of the no vote was discussed at the June 2016 international meeting held in Toronto.  Also discussed in Toronto were the 3000 comments that had been made internationally on the draft standard.  The development process is proceeding slowly because many of the participants are still  learning  how ISO management systems work.  These include traditional OH&S professionals and those representing organized labor.

Traditional OH&S Professionals

Traditional OH&S professionals make up a large portion of the members of the US TAG and the international committee.  Most of these members are new to management systems and do not understand how management systems work.  OH&S professionals are quite familiar with “compliance” to OSHA laws.  However, they sometimes struggle to understand that the purpose of a management system is to improve performance over time.  As a result the proposed Standard has become prescriptive including:

  • Requirements to use a Hierarchy of Controls when addressing OH&S hazards
  • Requiring more documentation than necessary
  • Inserting requirements that do not add value

Organized Labor

Organized Labor s a participant in the development of ISO 45001 and represent over 1 million members nationally.  One of the roles of organized labor has  been to help workers negotiate contracts between labor and management on compensation, benefits and workplace safety.   Labor has adopted the position that ISO 45001 should be a “workers’ rights” standard. Their approach to providing input to the ISO 45001 development process is like a contract negotiation.

This has created tension at both the national and the international levels.  Labor views the rest of the TAG as representing “management”.   When others on the TAG propose language that is not aligned with labors’ position, they voice strong  opposition. More then once labor representatives have accused other TAG members of wanting to “kill workers”.

What’s Next for ISO 45001

A committee was formed in Toronto to create the second draft international standard ISO/DIS2 45001:201X which is expected to be issued in the late fall to early winter.  We remain cautiously optimistic that both traditional OH&S and those representing labor will become more informed about the purpose of management systems and how they help organizations improve OH&S performance.  This in turn will help them participate more effectively in the consensus process.  If all goes well, a final international standard could be expected in mid-2017.

ISO 14001:2015 – What is a “Life Cycle Perspective”?

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The term” life cycle” is not new to most, but the use of the term “Life Cycle Perspective” (LCP) in ISO 14001:2015 (2015) is one of the bigger changes in the most recent revision.  Organizations transitioning to the revision must think carefully about how to use a life cycle perspective when planning the transition to the 2015 revision.  2015 requires the use of a life cycle perspective when it states:

Perspective

6.1.2 Environmental aspects
Within the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.

The previous version of 14001 (2004) only mentioned the term life cycle once in the Annex:

The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process

In 2015, the term life cycle appears 18 times, 7 of which are associated with the concept of perspective.  2015 does not explicitly define LCP stopping short and providing only a definition of term “life cycle”:

3.3.3
life cycle

consecutive and interlinked stages of a product (or service) system, from raw material acquisition or generation from natural resources to final disposal

Note 1 to entry: The life cycle stages include acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment and final disposal.

[SOURCE: ISO 14044:2006, 3.1, modified ? The words “(or service)” have been added to the definition and Note 1 to entry has been added.]

So the major questions are:

  1. How should organizations use a life cycle perspective when planning its EMS?
  2. What sort of evidence will auditors expect to see to confirm a life cycle perspective was used in planning an EMS?

Using a life cycle perspective when planning an EMS.

The introduction of 2015 provides some insight into what the standard means by Life Cycle Perspective when it states:

A systematic approach to environmental management can provide top management with information to build success over the long term and create options for contributing to sustainable development by controlling or influencing the way the organization’s products and services are designed, manufactured, distributed, consumed and disposed by using a life cycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle.

This statement suggests the purpose of using a life cycle perspective is to prevent the unintentional transfer of environmental impacts.  In order to do this, organizations need to expand their view of the impacts derived from their product and services beyond the property fence line.  Organizations need to look up their supply chain to understand the environmental impacts caused by their suppliers and those supplying their suppliers.   In doing so, the organization may be able to identify environmental impacts of which they had been previously unaware.  Armed with this new information the organization can then consider what, if any, control or influence they have over these supply chain environmental impacts.

Similarly, organizations will need to look down supply chains to identify environmental impacts that derive from the use of their products or services by their customers and end users. Also, they need to  evaluate their ability to control or influence these impacts..

Once these up chain and down chain impacts have been identified, 2015 expects that organizations endeavor to address the environmental aspects that are causing these impacts where practical.  How the organizations choose to address these life cycle aspects depends on several factors including:

  • the level of risk the aspect presents to the organizations
  • the level of risk the aspect presents to the environment
  • the degree of influence or control the organization has over the aspect

The amount of control or influence organizations have over life cycle aspects depends on:

  • how far up or down the supply chain is the aspect
  • how a design change will affect the performance or cost of the product
  • Who controls the design of the product or service

Organizations should also use a life cycle perspective when they are reviewing the potential environmental impacts and aspects from outsourced processes that are performed by other organizations on its behalf.

Evidence of a Life Cycle Perspective During Audits

Proving to an auditor that a life cycle perspective was used to identify the environmental aspects may be more difficult than actually using a life cycle perspective.  Based on early experience with 2015 certifications it is apparent that the certification community has not yet reached consensus on what and how much evidence is required to show conformance with the life cycle perspective requirements.  At minimum we recommend some discussion of how a Life Cycle Perspective was used perhaps in the high level documentation like an EMS Manual or in the documented procedure how the organizations addressed the requirements of Clause 6 Planning.

A graphic such as the one here describing the various life cycle stages may also be helpful in satisfying auditors need for evidence.Life Cycle Perspective ECSI copyright 2016

Unfortunately, and in the short term there is likely to be much variation between certification bodies and individual auditors regarding what is acceptable evidence of conformance the LCP requirements.  We encourage organizations to have a discussion up front with the auditors before the Stage 1 or transition audit about what the Certification Body (CB) and auditor will be looking for when collecting evidence that a LCP has been used in the EMS.