Water Scarcity and Greenhouse Gas Emissions Are Environmental Aspects Worthy of Management System Attention

Two of the most successful International Standards of the last 25 years are ISO 9001 and ISO 14001. ISO 9001, a quality management system standard now used by more than one million organizations, first gave international prominence to the “systems approach” to management. It has become one of the all-time best-selling standards of the International Organization for Standardization (ISO).

Its success helped launch ISO 14001, an environmental management system based on the “plan-do-check-act” virtuous cycle of policy-driven planning, managing to meet objectives, establishing operational control, and monitoring and measuring progress towards meeting identified objectives and targets. Several hundred thousand organizations around the world have adopted ISO 14001, usually as an enhancement of a quality management system which has the goal of managing processes for delivering quality goods and services and satisfying customers.

Fundamental to an environmental management system is the identification of the environmental aspects of an organization. These are the “elements of the organization’s activities, products and services that have or can have an impact on the environment,” whether adverse or beneficial. Identifying environmental aspects is key to the successful implementation of the management system, because it helps organizations proactively manage “those that can have a significant impact on the environment.”

Many early adopters of ISO 14001 environmental management systems reaped major benefits from their efforts. Energy efficiency, waste reduction, prevention of pollution, improved compliance with environmental legal requirements, all paid returns that contributed to the organizations’ bottom line while improving their standing among stakeholders, driving improvements through the supply chain, and augmenting workforce morale. Alas, the more the environmental management system standard became commonplace, the greater was the tendency of some later-adopting organizations to use the system as a regulatory compliance management tool and for little else.

In such cases, the true potential of the environmental management system is shortchanged. Properly implemented, ISO 14001-based systems should identify all environmental aspects that have the potential to create significant environmental impacts, whether they are currently regulated or not. Two prominent issues that fall in this category are water consumption and greenhouse gas emissions.

With the world population approaching seven billion, water scarcity is a growing concern. Organizations fortunate enough to be located in water-rich regions can ill afford to be complacent. Although “water wars” have not broken out recently in the United States, regions not normally considered water constrained have experienced some skirmishes. The contested northern boundary of the state of Georgia comes to mind, where claims of a flawed early nineteenth century survey that demarcated the boundary with Tennessee recently were raised. Why the sudden interest on behalf of the state of Georgia in a small strip of land that for nearly two centuries had been recognized as part of Tennessee? The explanation is access to the Tennessee River, which could have been tapped to relieve a drought that recently afflicted northern Georgia.

Another example is public opposition in Minnesota, the land of ten thousand lakes, to commercial development of the state’s water resources to feed an ever-expanding consumer thirst for bottled water. No thank you, say Minnesotans, who much prefer to keep their water for themselves.

Reducing greenhouse gas emissions is another issue that concerns many stakeholders. Regulation of greenhouse gas emissions is now occurring in California and has become an important consideration for the siting of new power plants across the country. For many companies, however, regulation of carbon dioxide is an issue for some time in the future, not today.

However, US companies ignore greenhouse gases at their peril. Aircraft operators landing in Europe or taking off from there face regulation from 2012 as part of an expanded European Union Emissions Trading System. This includes all US transatlantic carriers, and even some general aviation. France and other EU countries have proposed legislation that would mandate disclosure of the “carbon footprint” of products sold in that country from as early as January 2011. Imports from the US would be affected.

Identifying water consumption and greenhouse gases as potentially significant environmental aspects in an ISO 14001–based management system makes good business sense today, in advance of regulations. Doing so helps organizations take early actions to tackle critical issues before the mandates arrive.

© 2010, Futurepast: Inc.

Federal Trade Commission’s “Green Guides” Aim To Protect Consumers Against Misleading and Deceptive Environmental Marketing Claims

The US Federal Trade Commission is expected to extend the reach of its “Guides for the Use of Environmental Marketing Claims” when it updates the regulation codified at 16 CFR Part 260. Although FTC’s “Green Guides,” as they are commonly called, are provided only as guidance, organizations that make environmental marketing claims ignore them at their peril. The Federal Trade Commission Act grants the Commission the authority to file complaints against firms that engage in misleading or deceptive business practices. Under the law, the FTC can seek injunctions, issue cease-and-desist orders, and impose civil penalties. In practice, the majority of cases is settled without the imposition of sanctions.

The Green Guides help businesses make environmental claims that are truthful and verifiable. In the parlance of the FTC, companies making environmental claims should have a “reasonable basis” for doing so. FTC oversight extends to claims that are made both by businesses to consumers as well as to other businesses.

The Green Guides caution companies against making overly general claims like “eco-friendly.” Claims about recyclability should specifically state whether the claim applies to the packaging or to the product, or both. Enforcement actions by the FTC have increased under the administration of President Barack Obama. In 2009 the Commission filed three complaints against companies it said misused claims of biodegradability and four claims related to the purported environmental friendliness of clothing made from bamboo fibers. In the two terms of the George W. Bush administration, no complaints were filed against firms for misleading or deceptive environmental claims.

Some observers of the FTC hope the Commission’s updated Green Guides will address new types of environmental claims. At public workshops conducted in 2008, participants asked the Commission to expand the document to cover topics such as greenhouse gas emission reduction offset credits and Renewable Energy Certificates. Other environmental claims that have become common since the last issuance of the Green Guides address products that their marketers consider “sustainable” or “carbon neutral.”

The Commission’s Green Guides track closely ISO 14021, an International Standard published in 1999 with the title “Environmental Labels and Declarations—Self-declared environmental claims (Type II environmental labelling)” and adopted in 2001 as an American National Standard. Subcommittee 3 of ISO Technical Committee 207 is currently amending ISO 14021 and has before it some of the same issues that arose in the FTC’s public workshops.

ISO’s draft amended standard would allow qualified claims of “sustainable” or “sustainability” to be made as long as they can be justified in accordance with the 18 tests enumerated in clause 5.7 of the ISO 14021 standard. The draft amended standard addresses claims made about greenhouse gases, such as those relating to the “carbon footprint” of a product and claims that a product is “carbon neutral.” A new definition of “offsetting” refers to a “methodology by which the removal of CO2 from the atmosphere or prevention of emissions to the atmosphere from one process can be procured by the operators of another separate and unrelated process to counterbalance their own CO2 emissions that occur from the production or use of that process or product.” Claims that products composed of biomass are “renewable” are also discussed, as are claims related to “renewable energy.”

Given the past influence of ISO 14021 on the Green Guides, it can be reasonably expected that the FTC will take the amended ISO 14021 into consideration when finalizing its Green Guides revisions.

There are practical reasons for basing FTC guidance on International Standards. Primary among them is the influence that ISO standards have in international trade. When regulations adopted in the United States parallel ISO standards, actions the FTC takes to protect consumers against misleading or deceptive product claims are easier to sustain when challenged in bodies such as the World Trade Organization. Moreover, Congress in the National Technology Transfer and Advancement Act of 1995 instructed federal agencies to give preference when possible to voluntary consensus-based standards.

Futurepast is an active member of the US Technical Advisory Group to ISO Technical Committee 207, and is participating in the development of US positions related to the amended ISO 14021 standard. Futurepast provides expertise to clients on the development of environmental claims that can be substantiated in accordance with FTC Green Guides.

© 2010, Futurepast: Inc.

Top Five New Year’s Climate Change Resolutions for Organizations of All Types and Sizes

New Year’s resolutions may date back millennia, perhaps as far as early Babylonian times. In the modern era individuals may make solemn commitments to lose weight or exercise more. Meanwhile, organizations set about to achieve quality and environmental objectives while maintaining or improving financial performance metrics. Fortunately, when it comes to climate change resolutions, organizations—and individuals—can often achieve win-win outcomes. In this spirit Futurepast offers its Top Five Climate Change Resolutions for Organizations in 2010.

We rank as number five the establishment of an organizational inventory of greenhouse has emissions. For leading organizations, GHG inventories are not new. However, getting one is the place to start for organizations that have put off formal consideration of the carbon intensity of their operations and products. An inventory allows companies, governmental units, and other types of organizations the chance to quantify how much carbon dioxide equivalent gases they emit on an annual basis. The inventory is broken down by type of emission, such as Direct Emissions from stationary and mobile combustion, as well as process and fugitive emissions. Another category is Energy Indirect Emissions, which acknowledge how an organization’s demand for purchased electricity or steam frequently causes utility companies to combust fossil fuels to produce the energy an organization needs. A third category of accounts is Other Indirect Emissions which includes emissions associated with both the upstream supply of raw and processed materials an organization uses as well as the downstream effects of the products and services it furnishes to the market. Transportation of these materials, goods and services typically are also included in the upstream and downstream calculations. Definitely, if your organization doesn’t already have one, now is the time to establish an accurate and verifiable GHG inventory.

Number four on our list of resolutions for the New Year is to obtain information from your supply chain about the carbon intensity of their inputs to your organization’s activities. Leading companies like Walmart have pioneered in this field, and more and more market leading organizations understand the importance of doing so. It comes down to sustainability. Simply put, organizations that are not able to reduce their carbon footprint in the coming years run the risk of falling behind their competitors and losing market share. This is bad for them, their customers, and other stakeholders. Now that market leading organizations have inventoried their carbon emissions and considered ways to reduce them, the next logical place to look is in the upstream part of the value chain.

Our number three resolution is to use the organization’s inventory to set emission reduction targets. An inventory allows organizations to see clearly where their most carbon-intensive operations or activities lie. Armed with this information, objectives for performance improvement can be set. This typically occurs at the highest level of the organization during periodic exercises known as “management reviews.” Top management sets the direction, assigns responsibilities and time frames, and allocates the resources necessary to achieve the targeted improvements.

Futurepast’s second most important resolution for organizations this year is to communicate its GHG performance and improvement objectives to stakeholders. The audience for this communication is both internal and external. Employees must understand the message so they can take needed actions to meet the organization’s climate change objectives. Suppliers need to know what part of the value chain the organization has identified as bearing the highest potential for targeted emission reductions, so they may rise to the challenge and deliver them. Customers are an important audience as well, because increasingly they will make business-to-business or consumer decisions based upon least intensive carbon options, when all other factors are equal. Last but not least, the investor community has a growing desire to know how the organizations they own are meeting the climate change challenges of the twenty-first century. Indeed, in some cases, climate change disclosures may already be called for in securities regulations in those cases where a publicly traded company has determined that a reasonable person could be influenced by its climate change risks and management’s decisions about how to address them.

This year we cap our suggestions for resolutions with our number one recommendation: Reduce the carbon footprint of your organization’s activities and products. Implement actions that reduce consumption of energy, squeeze carbon emissions from the upstream supply chain, and reduce the carbon footprint of products over their life cycles. Increase the efficiency of lighting and heating/cooling systems, optimize distribution networks, reduce packaging, and improve recyclability. Encourage employee car-pooling, transit use or biking to work. Like the individual that goes on a diet and exercises more, organizations that produce equivalent products and services that use less materials and energy will gain an edge in the competitive marketplace and augment its appeal to customers. And in the classic win-win way, it will achieve these benefits while benefiting the organization’s bottom line.