Volume 8 · Issue 2 · February 2003
Contents
ISO 14001/4 CDs Out for Balloting
US TAG Gets Recommendation of "No" on ISO/CD2 14001
The second committee drafts (CD2s) for the revision of ISO
14001:1996 and ISO 14004:1996 have begun to circulate for
balloting and comment, but the US vote on the CD2 ballot for
ISO 14001 may not be for approval. The US Technical Advisory
Group (TAG) to ISO Technical Committee (TC) 207 and all other
participating member bodies (P-members) of the TC have until
April 7, 2003, to provide their votes and to submit comments
on the CDs.
Meanwhile, the US task group (TG) to TC 207’s WG 5 on
climate change submitted comments on February 13, 2003, on
the working drafts (WDs) of two standards on greenhouse gas
(GHG) emissions, with a call for a delay in the next WG 5
meeting to ensure there is adequate time to review the drafts
and develop national and international consensus before moving
forward.
In a letter to all TAG members dated January 31, 2003, Connie
G. Ritzert, Chair of the US Sub-Technical Advisory Group (SubTAG)
to Subcommittee (SC) 1, Environmental Management Systems,
and lead US delegate to SC 1, provided a February 28 deadline
for TAG members to provide votes and comments on each of the
two CD2s so that consensus US positions can be developed on
each when the TAG meets in Dallas March 10-11, 2003.
Two Different Recommendations
In addition, Ritzert provided the following recommendations
to the TAG based on "the input of the other individuals
who have been involved in the international deliberations
on these 14001 and 14004 revisions over the last few years":
- A "No" vote on ISO/CD2 14001, with both editorial
and technical comments
- A "YES" vote on ISO/CD2 14004 to move ISO 14004
to the Draft International Standard (DIS) stage, with both
editorial and technical comments.
Ritzert had the input of all the US delegates to Work Groups
(WGs) 1 and 2 of SC 1, which are responsible for the revisions
to ISO 14001 and ISO 14004, respectively: Jim Highlands, SubTAG
1 Vice Chair and WG 1 Expert; Phil Stapleton, WG 2 Convenor
and previous WG 2 Expert; Susan Briggs, WG 2 Expert; and Chris
Bell, previous WG 1 Expert. "The resulting recommendations
are not necessarily our personal positions but reflect our
collective experience at the international level and our understanding
of US interests based on past SubTAG deliberations,"
noted Ritzert in the letter accompanying the recommendations,
CD2s, ballots and comment templates. "They are intended
only to assist you in making your decisions about your votes
and comments."
Both CD2s were produced in Cancun in October 2002, although
there was a delay in circulating the draft revision of ISO
14001 to permit a survey of SC 1 P-members to ensure there
were no significant outstanding concerns that had not been
addressed in Cancun (for more information, see "ISO 14004
CD2 for Ballot Ready, ISO 14001 CD2 Awaits Survey", THE
OUTLOOK, October 2002).
"The international survey process resulted in support
for issuing ISO/CD2 14001, as we expected," confirmed
Ritzert in response to a question from THE OUTLOOK.
The version of ISO 14001 now circulating is therefore the
same one that came out of Cancun and on which the US provided
comments in responding to the survey.
The recommendation to disapprove of ISO/CD2 14001 with comments
is the result of concerns with the CD2. When drafting of the
revisions to ISO 14001:1996 began, there was international
agreement that the next edition of ISO 14001 would be drafted
to improve the clarity of the requirements and translatability
and to increase compatibility with ISO 9001:2000, but not
to make changes that result in the addition of new requirements
to the environmental management system (EMS) requirements
standard.
The agreement was modified somewhat by a resolution adopted
by WG 1 in response to a proposal from several P-members,
which essentially held that "new" requirements might
be added if they were needed for purposes of compatibility
with ISO 9001:2000. The US delegation had some success during
the addressing of comments on the first CD in reversing some
changes that introduced new language and potential new requirements.
However, the recommendation of a vote to disapprove with
comments is based on three major concerns with ISO/CD2 14001,
which THE OUTLOOK has summarized as follows:
- Subclause 4.3.2, Legal and Other Requirements, adds new
language that constitutes a new requirement to determine
how legal and other requirements apply to an organization’s
environmental aspects.
- Subclause 4.3.1, Environmental Aspects, contains new language
that creates uncertainty about the boundaries of an organization’s
environmental aspects and the extent to which certain aspects
must be addressed within its EMS.
- Subclause 4.5.3, Nonconformity and Preventive and Corrective
Action, contains new language to promote the use of preventive
action in line with ISO 9001:2000. While US SubTAG 1 supports
the emphasis on prevention, there is concern that the specific
changes made in the CD2 language will impose confusing or
unrealistic requirements.
"By comparison, the recommendation to approve ISO/CD2
14004 has to do with the fact that there have been significant
changes to ISO 14004:1996, but they have been generally favorable
to the US positions," acknowledged Ritzert in the US
SubTAG 1 recommendation.
"In particular, the US has had considerable input on
the changes made to Subclause 4.3.1 on Environmental Aspects…and
has participated in Editing Groups that have made significant
editorial improvements to the document…. Efforts have
been made to streamline the document (although more can be
done in this area) to ensure internal consistency and to ensure
consistency with the changes being considered to ISO 14001."
The SubTAG 1 Chair nevertheless encourages the TAG members
to provide comments for further improvement of ISO/CD2 14004.
"We believe there are several areas in the standard that
can benefit from additional changes, and we encourage TAG
members to submit comments so that consensus positions on
US recommendations can be reached at the March meeting."
THE OUTLOOK will provide more information on the CD2s
of ISO 14001 and ISO 14004 in future coverage and a report
on the US SubTAG 1 meeting March 10-11, 2003.
GHG Standards May Take Longer by Moving Too Fast
The US TG that is developing US positions and providing/supporting
US delegates to TC 207/WG 5, which was created for the drafting
of ISO standards on GHG emissions, submitted 48 pages of comments
on the following WD1s:
- ISO/WD1 14064-1, Principles and Requirements for Measuring,
Monitoring and Reporting Entity- and Project-Level Greenhouse
Gas Emissions and/or Removals
- ISO/WD1 14064-2, Principles and Guidelines for Greenhouse
Gas Validation, Registration, Verification and Certification.
The two WD1s are the outcome of a meeting of WG 5 in Berlin
in November 2002, at which four existing ad hoc groups (AHGs)
and a new Editing AHG examined evaluations of existing national,
regional and local GHG standards and other documents and sought
agreement on the content and an approach to the drafting of
an ISO standard(s) by WG 5. At that time, only one document
was in existence and was expected to be the basis of WG 5’s
output. Subsequent work by the AHGs resulted in development
of the two WD1s, which were received by the US TG in early
January 2003. Comments were to be submitted to the Secretariat
and Convenor of WG 5 by February 13.
Dr. Sergio F. Galeano and Dr. B. Tod Delaney, who are the
Co-Chairs of the US TG as well as US delegates to WG 5, sent
a request to the Secretariat and Convenor on February 3 that
the next meeting of WG 5, scheduled for March 2003, be delayed.
The short deadline for turnaround of comments, which also
made it impossible for the US TG to meet and develop consensus
positions on the WD1s, and some concerns with the content
and size of the WD1 documents were factors in the request.
Despite the fact that the Secretariat and Convenor could not
accept the US request because of the preparations already
made for a March meeting, the US TG leadership included in
the US comments a formal request for a delay until May 2003.
In the cover letter accompanying the US comments to WG 5,
Galeano stated the following in support of the delay:
As we signaled in our electronic communication of February
3, we are concerned that the very compressed schedule we
are operating under will actually decrease the likelihood
of achieving consensus and the prompt publication of ISO
GHG standards. Despite the best efforts of the Convenor
to distribute these documents, we had only a few weeks to
review, evaluate and comment on [them]. The situation was
further complicated by the unanticipated growth in the number
and size of the documents, from one document of less than
40 pages to two documents totaling over 80 pages. [ISO/WD1
14064-2] was a completely new document, with new, complex
and controversial content. Further, we will have only a
very short time to review what we expect to be the voluminous
comments from other delegations before the March meeting.
This rapid pace makes it very difficult, if not impossible,
to carefully and thoughtfully comment on the documents and,
more importantly, to build the national and international
consensus necessary to a successful conclusion of this process.
Moving too fast and not building consensus through a transparent
process as we proceed will likely create major delays if
draft standards are voted down at an advanced stage.
Accordingly, the US requests that the meeting scheduled
for March be postponed until May to provide all participants
more time to review, evaluate and communicate about these
documents. We…believe that being slightly more deliberate
at this stage will ultimately make meetings more efficient
and convenient and speed the process up by making consensus
more achievable.
Among the key points reflected in the US comments were the
following:
- The ISO GHG documents need to remain "regime neutral"
(i.e., they don’t correspond specifically to one country’s
or sector’s regulatory approach to GHG emissions) so
that they can be used in the full range of international,
regional, national and private GHG schemes
- ISO/WD1 14064-1 departs significantly from the "seed
document" that was the focus of attention in Berlin
and from the understandings reached at the Berlin meeting’s
conclusion on concepts and formats for the GHG standards
- The Berlin meeting concluded with the understanding that
there would be one standard, not two. That having been said,
the comments identified "major deficiencies" in
ISO/WD1 14064-2, including that it is:
- Not regime neutral—it essentially reflects an
emissions trading system (ETS) regime used in the United
Kingdom
- Based almost entirely on an assumption that organizations
will use external, third-party verification, which is
inconsistent with the content and approach of ISO/WD1
14064-1 and agreements reached at prior meetings of
WG 5 and its predecessor, the Climate Change Task Force
(CCTF)
- Excessively detailed and prescriptive and imposes
an unnecessarily complex and bureaucratic process not
suitable for entities
- Not drafted so that its content is coordinated with
that of ISO/WD1 14064-1 (e.g., many terms are defined
differently) and contains text on monitoring/measuring
that does not belong in the discussion of validation/verification.
It is likely that WG 5 will meet in March 2003 as planned,
although it is not yet known whether other countries participating
in the development of these ISO GHG standards will submit
comments similar to those of the US TG in content or number.
THE OUTLOOK will provide coverage of developments within
WG 5, as appropriate, whether WG 5 meets in March or the US
TG to WG 5 meets in Dallas March 10-11 as part of the meeting
of the US TAG to TC 207.
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