Over the past decade an increasing number of companies and government institutions have implemented formal environmental management systems (EMS) as a process to effectively manage regulatory requirements and reduce pollution. There are a number of different EMS process approaches; however the ISO 14001 international voluntary standard introduced in 1996 has gained the greatest following. Currently, there are approximately 1,700 U.S. and 37,000 worldwide businesses and other facilities registered as conforming to the ISO 14001 standard.

This new approach to voluntary environmental protection has many supporters calling for the EPA to support a cooperative effort to assist firms with EMS interventions by offering a variety of incentives and resources. Advocates claim that the framework of an EMS provides opportunities for improved environmental performance and compliance. In addition, many proponents are convinced that a facility with an effective EMS will operate more predictably and yield environmental performance, while at the same time reduce the government's inspection and enforcement costs. Thus, it is argued, allowing the government to redirect scarce regulatory resources toward higher risk facilities.

Opponents, who dispose the likelihood that an EMS will result in better environmental performance, disagree that environmental management interventions allow business to perform better than under regulatory coercion. Furthermore, many believe that it is the social responsibility of business and industry to fund their own environmental initiatives, especially if the outcomes are suspect.

The EPA's response to this debate was one of gathering more information and primarily consisted of a major study designed to better understand the effectiveness of an EMS to improve environmental performance. The study was commissioned in 1998, through the University of North Carolina at Chapel Hill, with the objective of developing a national database that provides a preliminary answer to a single overall question, "What effects does the implementation of an EMS have on a facility's environmental performance, regulatory compliance, and economic performance?"

The study was designed around seven major themes of an EMS: EMS Design and Implementation; Existing Management Systems; Environmental Performance; Regulatory Compliance; Use of Pollution Prevention Techniques; Involvement of Interested Parties; and Economic Performance (Costs and Benefits).

Results from the study, released in January 2003, denote that environmental performance indicators (quantifiers for measuring progress) showed a clear pattern of improvement over the time span of five-years, however, these advancements were not exclusive to those associated with EMS objectives and targets. This implies that environmental performance improvements are the result of a broad-based premise that, according to the study, is influenced by "raising the attention of all employees toward opportunities for environmental performance improvements."

Therefore, if the goal of an EMS is to move beyond regulatory compliance, it should not only focus internal resources on machination and control, but must also consider people, beliefs and progressive approaches for shifting attitudes by creating a willingness to change.

Therefore, an effective EMS must consider "the attitudes of managers (to include environmental considerations in their calculations), the process of making decisions (promoting wider participation, and more inclusive agendas and priorities), the structure of facility management (by assigning new environmental responsibilities, creating and tracking indicators, etc) and perhaps even the functions performed by a given facility (by adding environmental stewardship to its mission)" (North Carolina EMS study, 2003).

This finding suggests that less than optimum benefits (potentially only regulatory compliance and low hanging fruit) are gained from an EMS that does not incorporate an organizational change intervention. As a result, the EPA will not rush to covet an EMS in lieu of a regulatory coercive approach. As more research is conducted and companies institute, refine and revise their EMS initiatives to include organizational behavioral change, improved environmental performance associated with an EMS intervention may be better quantified and correlated. If and when this occurs, the EPA will have to consider the debate at the policy level.

For more information on the EMS study: http://ndems.cas.unc.edu/