Successful Practices

of Environmental Management Systems

in Small and Medium-Size Enterprises

Commission for Environmental Cooperation

A North American Perspective
The Commission for Environmental Cooperation (CEC) was established under the

N o rth American Agreement on Environmental Cooperation (NAAEC) to address envir o n m e n tal issues in North America from a cont i n e n tal perspective, with a pa rt i c ular focus on those arising in the context of liberalized trade. 

This publication was prepared by the Secreta r i at of the CEC. The views conta i n e d

herein do not necessarily reflect the views of the CEC, or the governments of Canada,

Mexico or the United States of America.

Reproduction of this document in whole or in pa rt and in any form for educational or

nonprofit purposes may be made without special permission from the CEC

S e c r e ta r i at, provided acknowledgement of the source is made. The CEC would

a p p r e c i ate receiving a copy of any publication or material that uses this document as

a source.

Commission for Environmental Cooperat i o n

393, rue St-Jacques Ouest, Bureau 200

Montréal (Québec) Canada H2Y 1N9

E-mail: info@cec.org

h t t p : / / w w w . c e c . o r g

ISBN: 2-923358-29-5

© Commission for Environmental Cooperation, 2005

Legal Deposit-Bibliothèque nationale du Québec, 2005

Legal Deposit-Bibliothèque nationale du Canada, 2005

Disponible en español - Disponible en français

Design: Associés libres, Montreal

December 2005

Printed in Canada on paper containing 100% postconsumer waste fiber.

This report was prepared by Tim Whitehouse, Head of the Law and

Policy Program of the Secretariat of the Commission for

Environmental Cooperation (CEC). Morgan Rider, member of the

environmental consulting firm Ecology and Environment, Jerry

Speir, an attorney practicing in New Orleans, Louisiana, and Dixon

Thompson, professor of environmental science at the University of

Calgary’s School of Environmental Design assisted in the design,

research and writing of this report.

The Secretariat is grateful to Environment Canada, Mexico’s

Federal Attorney for Environmental Protection (Procuraduría

Federal de Protección al Ambiente) and the US Environmental

Protection Agency for their comments on this report. The views

expressed in this report are not necessarily those of the governments of Canada, Mexico or the United States.

Peer reviewers also provided extremely valuable comments

and ideas during the development of this report. They provided

many insights into the issues faced by small and medium-size businesses in implementing environmental management systems and

into the types of resources available to help these businesses

improve their environmental performance. These reviewers were

Leonardo J. Cárdenas, Principal Consultores en Calidad Ambiental

SA de CV; Raymond P. Côté, professor, School for Resource and

Environmental Studies, Dalhousie University; Margarita Ferat Toscano,

environmental corporate manager, DESC SA de CV; Louise Millette,

director, Department of Civil, Geological and Mining Engineering,

École Polytechnique de Montréal; David Ronald, executive director,

Multistate Working Group; and Richard P. Wells, president,

Lexington Group.

A C K N O W L E D G M E N T S
C O N T E N T S

1. Introduction

2. Defining Small and Medium-Size Enterprises 

and Environmental Management Systems

3. Are Environmental Management Systems Effective?

4. The Benefits and Common Characteristics of Successful

Environmental Management Systems

5. Drivers and Barriers to EMS Adoption by Small 

and Medium-Size Enterprises

6. Technical Assistance and Outreach

7. Incentive Programs and Policies

8. Future Directions

Appendix A. Useful Web Sites

Appendix B. 10 Elements of an Environmental 

Management System

References

2

4

9

12

15

18

24

27

29

30

31
2 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S

T

his report examines the use of environmental

management systems (EMSs) in small and

medium-size enterprises (SMEs) in Canada,

Mexico and the United States. In doing so, it provides a North American perspective on successful practices and some of the issues faced by

SMEs in developing and implementing these systems. It also offers some suggestions for continued cooperation between the governments of

Canada, Mexico and the United States on promoting EMSs. 

Over the past decade, the three governments have promoted the use of EMSs to help

companies improve their environmental performance and move beyond compliance with

the law. The Commission for Environmental

Cooperation (CEC) has served as a forum in

which the three governments could share their

experiences, practices, and successes on the use

of EMSs in North America. In June 2000, for

example, the CEC published Improving Environmental Performance and Compliance: 10

Elements of Effective Environmental Management Systems, which described those elements

that the three governments agreed were important to address in implementing EMSs (CEC

2000). The CEC has also encouraged a North

American dialogue on the use of environmental

management systems through its support of

and participation in numerous workshops and

forums, including most recently those of the

North American Pollution Prevention Partnership, Mexico’s Pollution Prevention Roundtable,

the Auditing Roundtable and the Canadian

Environmental Auditing Association. 

In recent years, the private sector has developed various types of EMSs for identifying and

managing the impacts that commercial, industrial

and service operations have on the environment.

Although the use of EMSs is becoming more

common among larger companies, their use by

small and medium-size enterprises is less comm o n .

A successful EMS can enhance efficiency

and lower costs, reduce resource use and waste,

help to ensure compliance with regulatory

requirements, encourage employee involvement

in environmental performance and improve relations with customers. In examining a variety of

experiences in North America, this report identifies six common characteristics of successful EMSs

adopted by small and medium-size enterprises:

1. designed with a strong business case in mind 

2. managerial support and commitment of

r e s o u r c e s

3. engaged employees

4. integrated into business

5. clearly defined objectives and targets

6. continual monitoring and measurement.

Not all EMSs, however, are effective in

improving environmental performance. Most

SMEs face few incentives and many difficulties

in implementing environmental management

systems. The owner of a business must believe

that an EMS will create real tangible value for

the business. Yet most SMEs do not know what

an EMS is and, if they do, how it could benefit

their business. Even if they are familiar with the

concept of an EMS, many smaller businesses

lack the technical expertise and resources

n e e ded to develop and implement one. 

Although business needs may ultimately

determine whether an SME implements an EMS,

government or private sector technical assistance

and outreach efforts are often crucial to providing the conditions under which businesses—particularly small and micro-businesses—are likely to

implement a successful EMS. Continued c o o p e ration among the governments of Canada, Mexico

and the United States could help improve the

delivery of sector-specific information and technical assistance and specific advice on EMS

methodologies to SMEs. 

Organization of This Report

The chapters that follow describe a North

American perspective on the use of environmental management systems in small and medium-size enterprises. The definitions of an EMS

and a SME in Chapter 2 are followed by a closer

look in Chapter 3 at the effectiveness of environmental management systems in improving

environmental performance. Chapters 4 and 5

then look at the benefits and characteristics of a

successful EMS and the drivers and barriers to

EMS adoption by small and medium-size businesses. Chapters 6 and 7 review the technical

assistance and outreach, and the incentive programs and policies in the three countries. Chapter 8 concludes by examining areas for future

cooperation by the three governments on EMS

promotion in North America. The two appendices to the report provide general information

1. INTRODUCTION
3 A N O R T H A M E R I C A N P E R S P E C T I V E

on environmental management systems.

Appendix A lists some useful web sites in addition to those found as reference to this text, and

Appendix B presents the CEC’s "10 Elements of

Effective Environmental Management Systems."

With the growing integration of the North

American economy under the North American

Free Trade Agreement (NAFTA), the CEC is in a

unique position to step back and examine the

development of EMS policies and programs in

all three countries. Such an examination can help

those promoting environmental management

systems in Canada, Mexico and the United

S t a t e s to learn from the experiences of the other

countries and can help to inform and stimulate

discussion and critical comment among t h o s e

assisting small and medium-size enterprises w i t h

environmental issues.
4 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S

S

mall and medium-size enterprises in North

America vary widely in their impacts on the

environment. An environmental management

system offers the methodology a company

needs to identify and implement ways in which

to improve the environment both inside and outside a plant or business, from mere good housekeeping steps to strategies to prevent pollution.

This chapter examines the various definitions of small and medium-size enterprises and

some of the different types of environmental

management systems in the three countries.

Although the definition of a small and mediumsize enterprise varies from country to country, it

is useful to examine SMEs as a general category.

These kinds of enterprises generally have fewer

resources to address their environmental impacts

and are thought to be less likely to implement

EMSs than larger companies. They also do not,

by most definitions, have a parent company on

which to rely for assistance. Despite these limitations, SMEs can use the basic methods of

implementing an EMS as described in this c h a pter to integrate environmental planning into their

everyday business practices. 

What are Small and Medium-Size 

E n t e r p r i s e s ?

SMEs are found in the largest and most dynamic

sectors of the North American economy, ranging from those that are pollution-intensive and

resource-intensive, such as manufacturing and

natural resource extraction, to those that are

more environmentally benign, such as retail. They

often face unique environmental c h a l l e n g e st h a t

are related to their size and their place in the

economy. (See Table 2.1)

The economic importance of SMEs in

North America is significant. Over 98 percent of

businesses in Canada, Mexico and the United

States are small and medium-size enterprises.

SMEs are found in all the economic sectors of

the three countries, producing approximately 40

percent of their gross domestic product (GDP)

and over half of their private sector employment.

In the manufacturing sector, SMEs generate 55

percent of manufacturing employment in Canada,

66 percent in Mexico and 41 percent in the

United States (OECD 2002).

Although most SMEs serve local markets,

they are increasingly operating as part of a global marketplace, purchasing products produced

abroad, supplying multinational companies and

selling directly to overseas buyers. In North

America, SMEs play an important role in the

market-driven coordination of production across

the US-Mexico and US-Canada borders, especially in sectors such as automobile, telecommunications equipment, computer, electronic

products and textiles and apparel. 

SMEs face widely differing environmental

issues based on the economic sector, employee

base and jurisdiction in which they operate. The

requirements, demands, pressures and issues

they face will more often resemble those faced

by companies in their own economic sector,

regardless of size, than those in other sectors.

In addition, within the SME category differences often exist in the technical capabilities of

small and medium-size businesses, with medium-size business much more likely to have

engineering expertise than small enterprises,

especially related to energy efficiency and cons e r v a t i o n .

SMEs, even those in the retail sector, can

have significant impacts on the environment,

including those from nonregulated activities

such as resource consumption, packaging and

methods of hazardous and nonhazardous waste

disposal. According to Environment Canada

(2003), of the 2 million Canadian SMEs, the

400,000 most pollution-intensive are in the agriculture, primary and manufacturing sectors.1 A

Table 2.1 Distribution of Employment in Manufacturing by Size Class

Country 0–9 10–49 50–99 100–499 500+ Total

Canada 4.1 17.8 8.8 24.2 45.0 100

Mexico 18.9 12.0 7.5 27.6 34.0 100

United States 3.6 4.1 16.0 17.4 58.9 100

Source: OECD 2002.

2. DEFINING SMALL AND MEDIUM-SIZE

ENTERPRISES AND ENVIRONMENTAL MANAGEMENT

SYSTEMS 

Small and Medium-Size Enterprises?

The threshold of 500 employees guides the

classification of small and medium-size enterprises (SMEs) in Canada, Mexico and the

United States. Environment Canada typically

classifies enterprises with less than C$50 million in annual revenues that are not wholly

owned subsidiaries as follows: less than 5

employees, microenterprise; 5–49 employees, small enterprise; 50–499 employees,

medium-size enterprise (Environment

Canada 2003). 

The medium-size category is not commonly used in the United States, and the U S

Environmental Protection Agency considers a

small business for research grant programs to

be a for-profit organization with no more than

500 employees that is not dominant in the

field of operation. For Performance Track

Purposes (see Chapter 7), a small business is

defined as a facility with fewer than 50 employe e s. These facilities may be part of larger

organizations. The US Small Business

A d m i n i s t r a t i o n has devised sector-specific definitions with both employee and revenue limits.

See <http://es.epa.gov/ncer/sbir/

2005SBIRfactsheet.pdf> and

<http://www.sba.gov/size/>.

In Mexico, Profepa follows a classification

(by number of employees) established by the

Secretary of Economy in 1999:

Industrial CommercialService

Micro 0–30 0–5 0–20

Small 31–100 6–20 21–50

Medium 101–500 21–100 51–100

Mexico’s National Institute of Statistics,

Geography and Informatics Instituto Nacional

de Estadística Geografía e Informática—

INEGI) has more specific classifications.

1. The primary sector includes activities such as fisheries, mining,

forestry and oil and gas extraction.
5 A N O R T H A M E R I C A N P E R S P E C T I V E

study prepared for the Organization for Economic

Co-operation and Development (OECD) found

that SMEs in the United States are significant

contributors of pollution in three branches of

manufacturing: chemicals, primary metals and

building materials (e.g., stone, clay and glass).

The largest impacts from these SMEs were on

biological oxygen demand (BOD) in water and

suspended particulates in air, followed by the

release of toxic chemicals (OECD 2002). But

those statistics for the United States were d e v e loped in a study done specifically for OECD;

generally, "comprehensive pollution or resource

consumption statistics for SMEs do not exist,

making it difficult to determine their contribution

to environmental degradation" (OECD 2002).

What Is an Environmental Management

S y s t e m ?

An environmental management system is a tool

used by a company to identify measure and

manage the effects of its activities on the environment. An EMS sets out the company’s goals

for environmental performance and a plan for

achieving those goals. Ideally, company managers will set goals in areas such as compliance

with environmental laws, minimization of risks

to human health and the environment, use of

natural resources, and prevention and reduction

of pollution. 

The evolution of EMSs in North America

can be traced to the 1970s and the pollution

prevention programs of companies such as 3M,

with its "Pollution Prevention Pays" program,

and Dow, with its "Waste Reduction Always

Pays" (WRAP) program. In the 1980s, EMS programs largely focused on due diligence and

compliance with laws and regulations as well as

ways to cut costs in disposing of wastes and

treating effluents. Also in the 1980s, trade associations began to develop codes of environmental practices, which approximated the

definitions of environmental management systems (Pacific Institute for Studies in Development, Environment, and Security 2000).

EMS Models 

Today, EMSs can range in complexity from simple reminders of regulatory deadlines at a single

facility to an elaborate, Internet-based, enterprise-wide performance management system

that tracks regulatory requirements, assigns

tasks, controls documentation and records, provides training, and shares information across multiple operations and facilities around the world.

EMSs are most effective when they are

part of normal business activities rather than

treated as separate programs or initiatives.

Although businesses typically have many elements of an EMS already in place, the EMS provides a systematic way to integrate those efforts

and direct them toward company-established

goals. The significant range and variations of

EMSs can be attributed to the differences

among organizations in size, activities, impacts,

regulatory requirements, corporate culture and

Figure 2.1 BC Hydro’s Environmental Management System

Total Quality Management 

Most systematic approaches to addressing

performance issues derive from the work of

W. Edward Deming, the US statistician who

is credited with dramatically improving the

performance of Japanese industry after World

War II with a system that has come to be

known as Total Quality Management (TQM).

Deming also popularized the plan–do–

check–act cycle that is at the root of all such

systems: identify and analyze the problem

(plan), develop and implement solutions (do),

evaluate and measure the results (check), and

fix the problems identified and incorporate

the lessons learned into a feedback loop that

begins the process anew (act). The feedback

loop involves all personnel and elements of an

organization and runs counter to traditional

top-down "management by objective"

approaches. Environmental management systems turn the TQM process to a specific concern for reducing environmental impacts.

Source: Welch 1998.

Environmental

Responsibility Policy

Planning

• Identifying aspects, impacts

and operational controls

• Indentifying legal and other

requirements

• Meeting objectives, targets

and environmental programs

Implementing and Operation

• Defining training needs

• Implementing training

• Internal communication

and reporting

• External communication

• Document control

• Contractors and suppliers

Checking and Corrective Action

• Monitoring and measuring

• Process improvement

• Records

• EMS compliance audits

Management Review

EMS

Source: Industry Canada,

<http://www.strategis.ic.gc.ca/epic/internet/

incsr-rse.nsf/en/rs00122e.html>.
6 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S

policy commitments. Figure 2.1 depicts the

EMS of BC (British Columbia) Hydro and is representative of the structure of many EMSs.

The International Organization for 

S ta n d a r d i z ation (ISO) 14001 

The most widely recognized model for an EMS

is the International Organization for Standardization (ISO) 14001 standard. This standard,

which is applicable to organizations of all types

and sizes, is based on five components:

1. An environmental policy that commits the

organization to "prevention of pollution," "continual improvement" and compliance with "relevant environmental legislation and regulations."

2. P l a n n i n g to implement the environmental

policy, which entails identifying all of an organization’s interactions (activities, products or services) with the environment (its "environmental

aspects") and designating the "significant"

aspects and setting quantifiable objectives and

targets for addressing those significant aspects.

3. Implementation and operation, which

r e q u i r e s an organization to ensure the availability of resources, define roles and responsibilities,

develop documented procedures, emergency

preparedness plans and ensure employee competency, training and awareness.

4. Checking and corrective action to measure

and track the performance of the system against

its own goals and to evaluate compliance with

the relevant laws and regulations. The organization must also identify, investigate and correct

any nonconformities. The organization must

ensure that internal audits are conducted.

5. R e v i e w of the EMS by top management "to

ensure its continuing suitability, adequacy, and

e f f e c t i v e n e s s . "

The ISO standard focuses on conformance

with established policies, plans and procedures,

but it does not specify requirements for environm e n t a l performance beyond compliance with the

r e l e v a n t legislation. Organizations are, however,

free to set goals that exceed compliance

r e q u i r e m e n t s .

Companies implementing ISO 14001 may

c h o o s e to have their EMS certified. They can seek

third party certification from either accredited

certificate bodies (those recognized by a national

accreditation body) or no accredited bodies. Most

firms seeking certification employ accredited

bodies; these may be perceived on the market as

having greater credibility, although a firm that

implements ISO 14001 solely for internal management purposes (without expectation of benefits from regulators, customers or public

perception) may choose not to seek third party

certification by accredited certificate bodies.2

The European Office of Crafts, Trades and

Small and Medium-Sized Enterprises for Standardisation (Le Bureau Européen de l’Artisant,

et des Petites et Moyennes Enterprises pour la

N o r m a l i s a t i o n), better known by its acronym

NORMAPME, has formally asked the ISO to

"explore alternative ways to use the environmental management system standard ISO 14001

that are in line with their members’ limitations."

NORMAPME seeks changes that might include

allowing an incremental implementation of ISO

14001 or allowing organizations to be certified

in batches, sharing procedures and administrative costs. The ongoing revisions of ISO 14004

are intended to simplify EMS requirements for

SMEs in order to facilitate implementation. ISO,

through its Sub-Committee 1 of Technical Committee 207, has formed an ad hoc group to study

EMS penetration among small businesses, and a

report is expected in September 2005.3

The Eco-Management and Audit Scheme

Many European countries require large m a n u f a cturing facilities to implement the Eco-Management

and Audit Scheme (EMAS). The components of

EMAS are similar to those of ISO 14001. However,

EMAS has two significant additions: a baseline

environmental assessment and a public environmental performance report. Many companies

outside Europe have also chosen to implement

the EMAS system or variations.

The CEC’s "10 Elements of Effective Environm e n tal Management Systems"

In June 2000, the Commission for Environmental Cooperation published the "10 Elements of

Effective Environmental Management Systems"

(CEC 2000). The "10 elements" were negotiated

by Canada, Mexico and the United States just

after the ISO 14001 standards were published

and served as the first general policy statement

by the three governments on what they

believed were important features of an EMS.

The "10 elements" are generic in nature and not

specifically geared toward small and mediumsize enterprises. Notably, they place greater

emphasis on compliance with environmental

regulations than the ISO 14001 standard. Like

the ISO standard, the "10 elements" state that a

company’s environmental policy should include

a provision for compliance with environmental

requirements. But the "10 elements" go beyond

the ISO in stating that an EMS should establish

ISO 14001 Trends in North America

As of December 2003, the breakdown of

North American certifications for ISO 14001

was Canada, 1,274; Mexico, 406; and the

United States, 3,553 By contrast, in 1998 the

breakdown was Canada, 104; Mexico, 39;

and the United States 291. See

<http://www.iso.org/iso/en/iso9000-

14000/pdf/survey2003.pdf>. No specific

numbers exist for SMEs, which are more 

likely to use third-party registrars and 

therefore are less likely to be reported 

in the ISO system.

2. For more on ISO certification, see <http://www. iso.org/iso/en/

iso9000-14000/basics/general/ basics_5 . h t m l>.

3. See <h t t p : / / w w w . i s o . o r g / i s o / e n / C a t a l o g u e D e t a i l P a g e .

C a t a l o g u e D e t a i l ? C S N U M B E R=3 1 8 0 8>.
7 A N O R T H A M E R I C A N P E R S P E C T I V E

objectives and targets for achieving and maintaining compliance with environmental requirements and a commitment to continuous

improvement in environmental performance

(see Appendix B for the CEC’s "10 elements").

A Sample EMS from the Metal Fi n i s h i n g

I n d u s t r y

Various sample EMSs are available for small and

medium-size enterprises. The most useful samples tend to be those tailored to a specific

industry and designed with input from the

industry itself. For example, the Texas Commission on Environmental Quality (TCEQ) developed

a sample EMS for small businesses in the metal

finishing industry. (See Table 2.2) The EMS for

the fictitious company, Papa Plating, covers all

on-site operations, including metal finishing and

processing activities, groundskeeping, offices

and waste disposal.

Table 2.2 Selected Aspects of Sample EMS Addressing Water Usage 

Form 7: Environmental Management Action Plans

Significant Environmental Aspects Water Use

Goal Reduce the amount of water purchased by 50%

Action Plan Analyze how water is used and what can be done to 

minimize water use

Consider different potential rinsing methods

Review Cycle Willie Scott will review every 6 months

Form 8: EMS Work Instructions

Form 9: Alternatives Identification — Significant Environmental Aspect: Water Use

Water Use

Parts Rinsing

Parts Racking

Plating supervisor

Plating supervisor

Significant Environmental

A s p e c t s

Associated Job 

F u n c t i o n s

Rinsing methods

Water flow

Treatment

Rinse tank 

Dip rinsing

Rinse water is being

flowed at a high rate 

during production

Currently chemically treated

and discharged to wastewater treatment facilities

None

Try spray rinses in the various processes to try

to improve rinsing performance and decrease

water consumption

Research the use of conductivity meters

and/or flow restrictions

Consider the use of reverse osmosis and/or ion

e x c h a n g e after the initial treatment and reuse

the treated effluent back in our process 

Consider the use of air agitation in the rinse

tanks to improve agitation the rinsing process

A c t i v i t y Current Practice Potential Alternatives

Responsible Person

Yes – employees should

monitor the drip time over

the various rinse tanks and

withdraw the parts at the

proper speed

Yes – employees should

rack parts to minimize

solution dripping on other

parts 

Work Instructions 

N e e d e d

Source: TCEQ
Papa Plating’s EMS contains elements of

ISO 14001 and the CEC’s "10 elements." The

EMS provides a sample action plan on water

use, energy use, sludge generation and disposal, metal use and use of natural resources,

organic emissions from a degreaser and human

exposure to toxic materials and chromium emissions. A look at the selected portions of an EMS

regarding water aspects of the Papa Platings

EMS usefully illustrates some of the specific elements of an EMS. 

Papa Plating’s system is just one example

of how to create an EMS. An environmental

management system can be designed to

address the needs of any size organization.

Standards groups, trade associations and governments have all designed different types of

environmental management systems and programs to help businesses improve environmental performance by integrating environmental

planning into everyday business processes. 

8 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S
9 A N O R T H A M E R I C A N P E R S P E C T I V E

R

ecent studies indicate that not all environmental management systems lead to

improved environmental or business performance. However, several projects and numerous

case studies of successful EMS practices in

small and medium-size enterprises support the

proposition that an effectively designed EMS

can, under the right circumstances, significantly

help a company improve its environmental performance and bottom line. Because not all

EMSs produce positive benefits, it is important

to understand the potential benefits of an EMS,

the common characteristics of successful EMSs,

the drivers and barriers to EMS implementation,

and the programs available to help SMEs

improve their performance. These subjects are

covered in the chapters that follow.

Empirical Studies of EMSs

Empirical studies of the performance of EMSs

have only recently begun to emerge. One of the

only studies in North America was conducted in

the United States by the University of North

Carolina and the Environmental Law Institute

between 1997 and 2002. The National Database

on Environmental Management Systems

(NDEMS) study examined environmental performance data at 83 facilities over a five-year

period. Ultimately, 30 facilities completed all five

years of the study. The participating facilities

ranged from large, publicly traded major manufacturers and electric utilities to small businesses

such as auto parts suppliers and electroplaters

and government organizations, including military

bases and municipal water treatment plants.

Approximately 70 percent of the organizations

participating in the NDEMS study were part of a

larger business or government organization.

The final report of the study concluded

that evidence from the pilot facilities "suggests

that the introduction of an EMS can be expected to be at least somewhat beneficial to the

environmental performance of most facilities, as

well as to their operating and management efficiencies, and in some cases to their regulatory

compliance patterns. These results are more

likely for facilities that are subsidiaries of publicly traded corporations, owing to their greater

access to management capabilities, resources,

and assistance from their parent organizations,

but they occur in privately held and government facilities as well." The NDEMS study is

inconclusive on the financial benefits of an

EMS, but notes that benefits were "moderately

impressive" for the facilities that realized them.

Thirty-two facilities reported quantified monetary benefits from EMS adoption; the average

net benefit for those reporting a benefit through

the first three years was $90,320. (NDEMS

2003) 

One study completed by the University of

Sussex in July 2000 compared EMS use in EMAS

and ISO systems in 280 European companies at

430 production sites and found no statistically

significant relationship between the adoption of

a formal EMS and improved environmental performance. The companies included 9 computer

companies, 58 electric power generators, 26 fertilizer manufacturers, 90 pulp and paper producers, 46 printers and 45 textile finishers.4

Another study of electronic firms observed

that firms that adopted ISO 14001 were able to

catch up to industry best practices, especially if

they produced significant toxic emissions

(Russo 2000). A study conducted in the automotive supply sector before Ford and General

Motors required their suppliers to be ISO-certified found minimal reductions after ISO 14001

adoption. In terms of toxic releases and compliance with regulatory requirements, environmental performance was about the same in

facilities that had adopted EMSs under ISO

14001 and those that had not (Matthews 2001).

Projects and Case Studies

Although little empirical work exists on the

impacts of EMS adoption, the literature and

case studies contain valuable information on

how companies have used EMSs to improve

environmental and business performance.

The US Environmental Protection

Agency’s web site includes a case study index

with links to EMS success stories, several of

them on SMEs.5 The EPA case studies generally

include an introduction to the facility, an

overview of the planning and implementation of

the EMS, a list of the benefits achieved, and a

description of the lessons learned. One case

study, for example, explains how the Mott’s

Aspers plant, an apple juice and apple sauce

plant with 378 full-time employees in Pennsyl3.ARE ENVIRONMENTAL MANAGEMENT SYSTEMS

E F F E C T I V E ?

An effectively

designed EMS can,

under the right 

circumstances, 

significantly help a

company to improve

its environmental

performance and

bottom line

4. See <http://www.environmental-performance.org/analysis/index.php>.

5. See <http://www.epa.gov/ems/studies/index.htm>.
10 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

vania, implemented a EMS that resulted in the

production of less solid waste, reduced water

usage, increased recycling, savings on energy

usage and wastewater treatment costs.6

The Manual for Implementing EMS in

S M E, issued by the International Finance Corporation (IFC), also includes 15 case studies

from facilities throughout the world, including

the United States, on the actual benefits realized by small and medium-size businesses that

have implemented EMSs (IFC 2004). Some

summaries of selected case studies from the IFC

manual appear in Table 3.1. 

In Mexico, several projects have been

undertaken to provide SMEs with technical

assistance in implementing environmental management systems. The Guadalajara Environmental Management Pilot (GEMP), financed by

the World Bank, studied the effects of EMS use

in small and medium-size enterprises in Mexico.

In this project, 11 large companies in Guadalajara, Mexico, signed a voluntary agreement with

Mexico’s Ministry of Environment, Natural

Resources and Fisheries (Secretaría de Medio

Ambiente, Recursos Naturales y Pesca— S e m a rnap), now known as the Ministry of Environment and Natural Resources (Secretaría de

Medio Ambiente y Recursos Naturales— S e m a rnat), to mentor small suppliers in implementing

EMSs. Within three months of completing the

formal EMS training, over 80 percent of the 20

participating companies in the GEMP study had

reduced their environmental releases, nearly 70

percent had improved their work environment,

and over 50 percent had improved their economic performance. 

Slightly less than 50 percent reported

improvements in waste handling, materials and

energy efficiency, and compliance. The study

c o n c l u d e s that "gains from good housekeeping

are potentially very large in the case of SMEs,

and ... an EMS provides a means to capture

Table 3.1 Selected EMS in SME Case Studies, Worldwide

Company Environmental Benefit Cost Savings

Leff-Marvins Cleaners Inc.

Company A

Mounstevens Ltd., a manufacturing and retail baker

Company B

Jamestown Paint Company

A manufacturer of power steering

gears, engine timing devices and

power transmission boxes

Replaced its old equipment with new system to

recycle PERC (perchloroethylene). Eliminated

most VOC (volatile organic compound) emissions and also reduced purchase of PERC from

200 gallons per month to 40 gallons per month.

Reduced hazardous waste stream from over

1,900 gallons of spent PERC per year to just 35

gallons of still residues per month.

Introduced more efficient ways of handling

cardboard. Reduced its waste by 577 tons in

the first year.

Increased staff awareness and introduced careful separation of waste.

Instituted a facility-wide municipal waste recycling program, including metal, cardboard,

paper, wood, plastic and glass. More than 50

percent of the municipal waste generated by

the company is now recycled.

Reduced its use of toluol by 95 percent and

xylol by 74 percent by developing water-based

products to replace solvent-based coatings.

Installed a green sand recycling system in its

foundry that puts recovered sand directly back

into the processing lines, recovering about 95

percent of silica sand.

The company realized a net savings of

US$1,400 per month with the new system.

Waste elimination bills were cut by 55 percent.

Saved staff time.

Expected benefits include cutting waste bills in

half and saving US$8,800 and 26 tons of waste.

Reduced disposal costs and gaenerated enough

revenue from marketing the recyclables to fund

the program’s operating expenses, including wages

and benefits, equipment operation and maintenance, utility costs and program improvements.

Information not available.

Reduction in the purchase of sand from 4 million pounds of sand per year to only 80,000

pounds per year, saving on sand purchase and

disposal costs.

6. See <http://www.epa.gov/ems/studies/mott.htm>.
11 A N O R T H A M E R I C A N P E R S P E C T I V E

these gains very quickly." The project’s preliminary findings indicate the following:

■ The ISO 14001 EMS model can be applied by

SMEs without any modifications, with the

exception of documentation.

■ Although the ISO 14001 EMS model is a p p r op r i a t e for SMEs, most SMEs require substantial

implementation support, particularly in the

areas of simplified formats, discrete milestones, management systems thinking and

staff assistance.

■ The business culture of a firm is probably a

more important factor than size in determining whether it can implement an EMS (World

Bank 1998).

Because the GEMP study was undertaken in the

early stages of EMS implementation, the longerterm economic and environmental affects of

EMS implementation have not been analyzed.

In another project, Proyecto Administación

Ambiental Monterrey (PAAM), undertaken in

Monterrey, Nuevo Leon, large companies and

the Multilateral Investment Fund of the InterAmerican Development Bank (IADB) supported

an effort by the Instituto Protection Ambiental

(IPA), a nongovernmental association of businesses in Monterrey, to train 19 SMEs in the use

and application of a modified environmental

management system based on the ISO 14001

model. One of the project objectives was to

determine whether EMSs were a useful tool in

improving SME environmental performance.

Four companies could to point to specific environmental and economic benefits of participating

in the project. The project’s report noted that the

vast majority of the "root causes" of significant

environmental problems identified by the firms

could to be addressed through changes in management practices such as improved maintenance, improved procedures and better training.

Relatively few of the solutions, according to the

report, required significant capital expenditures

(Lexington Group 2002). 

These studies and projects point the way

to understanding the potential benefits of an

EMS, while serving as a reminder that many

obstacles and barriers to effective EMS implementation exist.

Within three months

of completing the

formal EMS training,

over 80 percent of

the 20 participating

companies in the

GEMP study had

reduced their 

environmental

releases, nearly 70

percent had improved

their work environment, and over 50

percent had

improved their economic performance.
12 E N V I R O N M E N TA L M A N A G E M E N T S Y S T E M S

longer generating hazardous waste (IFC 2004).

In another example, during the development of

its EMS a company in Mexico, Químicos y

Papeles del Norte, identified the use of excessive rinse water as a significant environmental

aspect of its operations: the short production

runs of incompatible products required the

equipment to be rinsed between products. The

company implemented a more systematic production programming to eliminate product

changeovers and increased product storage

capacity. The results were more efficient utilization of product and storage space, water savings,

reduced product waste and improved labor utilization (Lexington Group 2002).

Reduced liability is another financial criterion

that can be used to measure the success of an

EMS. A court or the government may view a

company with an EMS in place more favorably

when determining sanctions. For example, in

Nova Scotia a judge dismissed a case against a

pulp and paper mill for a small oil spill because

the company had an EMS in place that addressed

spill issues. The judge cited the company’s due

diligence, stating "the supervisor who found the

leak . . . knew the equipment, what to do to

stop the leak and did so immediately. . . . He had

been instructed on what to do in the event of

any oil spill and he did that." R. v. Stora Forest

Industries Ltd., [1993] N.S.J. No. 330 (N.S. Prov.

Ct. Jun 23, 1993) Chapter 7 describes how g o vernment policies encouraging EMS usage may

also affect penalty calculations.

Reductions in Resource Use, Waste and

Emissions 

Many SMEs rate the success of their EMSs by

monitoring the resources used and the waste

minimized, both of which are closely related to

cost savings. Implementing an EMS allows a

company to identify opportunities for improvement and to plan expenses. Key performance

indicators include: the volume of raw materials,

water and energy consumption, recycling rate,

hazardous and nonhazardous waste generation

and the number and volume of releases. Organizations use self-generated records, bills or data

from various utilities to measure consumption

and waste pre- and post-EMS implementation.

Both large corporations and small and

medium-size enterprises use EMSs to reduce

resource and energy consumption, as well as

D

esigning and implementing an EMS can

have tangible benefits for business enterprises. A system can help a company to

enhance efficiency and minimize resource use

and waste, thereby reducing costs, help to

ensure compliance with regulatory requirements, encourage employee involvement and

improve relations with customers. Despite variation in the sophistication, scope and achievements of environmental management systems,

successful EMSs share common characteristics

that are directly related to the benefits of an

EMS. The benefits and the characteristics of

successful EMSs are described in this chapter.

The Benefits of Environmental 

Management Systems

Various books, articles and studies have identified the benefits an environmental management

system can have for a company. In this section,

these benefits are categorized into five main

areas that are most relevant to SMEs.

Enhanced Efficiency and Lower Costs

EMS manuals and case studies point most frequently to the financial benefits of implementing

an environmental management system. Cost savings are often linked with consuming fewer

resources and producing less waste, but savings

can also accrue from operational efficiencies, a

higher level of management efficiency, reduced

liabilities and shorter permitting times because of

better relations with regulators and communities. 

Operational efficiency usually involves

replacing or renovating equipment and facilities,

as well as improving the production process

design and paying closer attention to all inputs

and outputs. Such changes can reduce inputs

(energy, water, etc.) or make operations more

efficient, so that production is higher, faster or

cheaper than before. Costs are compared preand post-EMS implementation. 

Even small changes in operational efficiency

can produce significant results. During its EMS

identification process, one company highlighted

in the IFC case studies (Figure 3.1) noticed that

one of its large machines had a serious oil leak.

The leak was quickly repaired with a $5 gasket.

This easy, inexpensive action cut the amount of

oil consumed by the company by half, resulting

in significant cost savings. In addition, the local

municipal authority reclassified the plant as no

4. THE BENEFITS AND COMMON CHARACTERISTICS

OF SUCCESSFUL ENVIRONMENTAL MANAGEMENT

S Y S T E M S

Lower Insurance Costs

The most reliable financial quantification of

the benefits of an environmental management system is often lower insurance costs;

companies that minimize risks may receive

better insurance rates. The current case studies, however, provide only a few examples of

small and medium-size enterprises that realized this benefit. In one example, DESC, a

holding corporation in Mexico that owns several companies from different sectors, including the chemical sector, chose to expand its

company-wide EMS to include outsourced

carriers. As part of this effort, suppliers, customers, carriers, terminals and all who were

in the supply chain were evaluated. During

the first two years, the main focus was the

carriers, who were audited under a specific

risk reduction program. By developing tools

to evaluate the risks along its transportation

routes, DESC was able to achieve a substantial reduction in insurance fees. In turn, the

carriers, once they implemented these practices across their operations, were able to

negotiate a reduction in their own insurance.

Accidental index was reduced from six accidents in 2001 to zero in 2004. Part of the

evaluation tools used came from the

Responsible Care System of Mexico’s

National Association of the Chemical Industry

(Asociación Nacional de la Industria

Química—ANIQ) 

Source: Margarita Ferat Toscano, corporate environmental manager, DESC, SA de CV, e-mail message

to Ignacio González, CEC, 4 october 2004.
13 A N O R T H A M E R I C A N P E R S P E C T I V E

the volume and toxicity of waste generation.

Fourteen of 15 International Finance Corporation case studies claim reduced waste, consumption or toxicity as companies' main goals in

EMS design and implementation, as well as the

primary criteria for evaluating EMS usefulness.

Elsewhere, in a survey of 580 manufacturing

plants with more than 50 employees, Florida

and Davison (2001) found that facilities with

EMSs resoundingly pointed to recycling and

reductions in air emissions and solid waste and

electricity use as evidence of facility-level

i m p r o v e m e n t .

Regulatory Compliance 

Another frequent indicator of a successful EMS

is achieving the goal of regulatory compliance.

The criteria an organization selects to measure

improvement can vary widely and depends on

the company’s compliance history and regulatory burden. Management can use an EMS to

monitor the legal requirements and thereby plan

expenses associated with permitting, reporting

and monitoring to ensure compliance with the

law. Ideally reducing the frequency and severity

of violations and the associated costs. 

An EMS can also help a company to prepare for a more stringent application of environmental regulations by the government. For

example, the IFC case studies include the

example of a manufacturer of office furniture

that eliminated methyl chloroform from its

cleaning and fastening processes and reduced

the volume of emissions of volatile organic

compounds (VOCs) by converting to a powderbased coating system. These pollution prevention alternatives saved the company more than

$1.1 million a year and gave the company a

return on its $1 million investment in less than

one year. This effort helped the company to

comply more easily with increasingly stringent

environmental regulations and eliminated incineration fees for solid and liquid hazardous

wastes (IFC 2004).

Employee Involv e m e n t

Many companies recognize that the success of

an EMS depends on the participation of the full

spectrum of employees. Indeed, employee

engagement is at the heart of the Total Quality

Management (TQM) process on which EMS

principles depend. Different types of employees

have different insights into environmental performance and suggestions for improvements.

Proper implementation of an EMS requires

employee involvement and, if successful, creates as a benefit a sense of responsibility and

accomplishment among the employees.

A 90-person metal finishing company in

the United States, which was cited in the National Database on Environmental Management Systems study, designed its EMS without employee

involvement, but then engaged employees in a

series of classes and meetings to introduce and

reinforce EMS concepts. It also trained a dozen

employees from the company to act as internal

auditors. By contrast, another company cited in

the NDEMS study, a 350-person manufacturing

plant, selected a wide range of employees, from

managers to engineers to line operators, to

make up the team responsible for creating the

EMS. The company considered employee

engagement in the design process as important

as engagement in implementation.

Improved Relations with Custo m e r s

An EMS can improve relations with customers.

For an SME, improved relations usually means

larger purchasers in a dominant market position,

such as Ford and GM, which require their suppliers to be ISO 14001-certified. Smaller companies, however, may also find that an EMS means

wider appeal in a more local market. For example, Framboisière de l'Estrie, a berry farm in

Quebec, was one of the first two farms with ISO

14001 certification in North America (see sidebar). It markets its environmental improvements

and the positive economic benefits it has reaped

from ISO certification. 

The Benefits and Common Characteristics

of Successful Environmental Management

The success of an organization’s EMS can be

evaluated by monitoring the organization’s

progress toward meeting its environment-related objectives and targets. Understanding the

common characteristics of a successful EMS will

help to ensure that the conditions needed to

support successful EMS design and implementation are present. 

Designed with a Strong Business Case in Mind.

A successful EMS is developed with a strong

business case in mind. Its purpose is to improve

the value of the company through risk reduction, revenue enhancement and cost reduction. 

Supported by Management and Commitment of

R e s o u r c e s . Unless the owner and upper management are committed to and supportive of the

EMS, it is extremely difficult to obtain the

resources and cooperation needed to successfully develop and implement an effective system. The environmental policy, as endorsed and

supported by management, defines the strategy of the organization and specifies the scope

and commitments of the EMS to employe e s ,

customers and those outside the company, 

Fourteen of 15

International Finance

C o r p o r a t i o n case

studies claim reduced

waste, consumption

or toxicity as companies’ main goals

in EMS design a n d

implementation, a s

well as the primary

criteria for evaluating EMS usefulness.
14 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

such as local agencies, investors and community groups.

Engaged Employees. When employees at all

levels of an organization are engaged in an

EMS, it is more likely to succeed. Under a welldesigned EMS supported by management, individual employees understand their roles and

responsibilities, receive adequate training and

information, and are aware of the potential environmental impacts of their jobs. Typically, when

employees are engaged in such a program they

enjoy a sense of ownership and possess the

motivation to make a positive contribution to

the success of the program. 

Integrated into Business. The most successful

EMSs are not stand-alone projects or initiatives;

they are part of the standard decision-making

process of a business. They also are integrated

into all aspects of a company’s activities, products and services. In the NDEMS study, all c o mpanies that had adopted EMSs asserted that they

saw a business value in improving their environmental performance. 

Clearly Defined Objectives and Targets. S u c c e s sf u l EMSs tend to set both abstract/overarching

and specific/measurable goals. An abstract/

overarching goal may be "transparency," whereas a specific/measurable goal may be "Have

Michael document the EMS design and implementation process" or "Reduce air emissions by

35 percent by 2006." Abstract/overarching

goals allow for creativity and problem solving,

because managers and employees are not

bound to follow certain codes. Specific and

measurable goals ensure that the abstract is

translated into the feasible and achievable. This

duality also places smaller objectives in the context of larger goals.

Continual Monitoring and Measurement. M o n itoring and measurement are always cited in

EMS success stories, but companies go to widely different lengths to monitor and measure

their progress.

After setting objectives and targets, a company should devise a means of monitoring and

measurement, preferably in quantifiable terms.

Are changes being implemented? Are the correct policies being pursued? Is the amount of

waste being reduced, and, if so, by how much?

How much money is being saved through waste

reduction? Are targets being met? Are more

effective means of reducing waste available?

Should objectives and targets be revised? Questions like these should be asked daily by any

company and not limited to the start-up period

of the EMS. A key element of any management

system is the opportunity it provides for learning

from experience. Given the size, resources, and

variety of structures, as well as the obstacles

faced by small and medium-size enterprises in

implementing environmental management systems, it is important that those systems be flexible. Whenever possible, the goals and

complexity of an EMS should be set by the company itself. Those goals will necessarily be limited by financial and economic considerations,

including the profitability requirements of the

o r g a n i z a t i o n .

* * *

With these potential benefits, why aren’t more

SMEs designing and implementing successful

EMSs? One reason is that, in most cases, the

driving forces are not strong enough to overcome the barriers. It is essential that those promoting an EMS to such enterprises understand

the drivers and barriers faced by an SME. The

driving forces or barriers that are most important depend on the type of industry, the size of

the business and its customers. 

Improving the Value of the Raspberry

Business

Situated at Johnville, near Lennoxville,

Quebec, the Framboisière de l’Estrie s t r e t c h e s

over 11 hectares. Each year the farm grows

and sells 43,000 kilograms of fruit and markets associated products such as syrup. As a

result of going through the ISO process, the

farm did away with all pesticide use and

replaced fertilizers with compost, maintained

water consumption while increasing production surface by 50 percent and reduced the

cardboard content of its boxes by 50 percent,

which reduced its purchase, transportation

and storage costs. Overall, its production

costs decreased while yield increased.

The Case of Salsa de La Laguna

In adopting an environmental management

system, employee engagement and buy-in

can be particularly important when a compa -

ny has a recognized brand name. The

Guadalajara Environmental Management Pilot

(GEMP) study recounts the case of Salsa de

La Laguna (SLL), a 30-person Mexican company that makes hot sauce and supplies one

of the largest tequila manufacturers in Jalisco

with sangrita.

The company faced environmental issues

associated with excessive noise, the discharge of raw materials, generation of excessive waste, effluent discharges to a lake and

an excessive risk of fire. SLL developed a

comprehensive EMS by mobilizing work

teams to analyze and respond to problems in

industrial hygiene, raw material use and con -

trol of wastes, effluent discharges and noise.

Among the ideas that they, together with

management and a university consultant, had

were sorting solid waste into reusable and

recyclable bins, cleaning up work spaces,

improving the maintenance of company vehicles, reducing effluent discharges through

water conservation, reducing the use of sanitizing chemicals, requiring suppliers to use

strong containers in order to reduce waste

and loss, and rinsing out drums of orange

juice to salvage concentrate. Some of these

measures resulted in savings of over

US$10,000 a year. This new environmental

consciousness went beyond the factory.

According to the report on the project, some

workers "began wearing T-Shirts describing

their new environmental concerns, to speak

at local schools, and to participate in environmental cleanup activities in the community"

(World Bank 1998).
15 A N O R T H A M E R I C A N P E R S P E C T I V E

D

riving forces are factors that create or

change an organization’s environmental

performance by pushing it to utilize environmental management tools, including environmental management systems. The drivers are

usually directly related to the benefits articulated in the case studies in Chapter 4: enhanced

efficiency and lower costs; reduced resource

use, waste and emissions; regulatory compliance; employee involvement and improved

relationships with customers. Other drivers

might be motivators such as building relationships with government agencies, achieving

faster approval of projects, seeking fewer

inspections and less scrutiny, creating a good

public image and responding to pressures from

internal stakeholders within a company.

Unlike large companies with a recognized

brand name and large public exposure, smaller

businesses, especially suppliers to larger companies, are unlikely to implement an EMS as a

way enhance their reputation with the public.

The owner of the business must believe that the

EMS will create real tangible value for the business. When a strong business case exists, the

business owner’s active support for the design

and implementation of the EMS is critical to

help ensure its success.

Driver - Economic Fa c t o r s

An EMS can, in many instances, create real tangible value for a business in risk reduction, revenue enhancement and cost reduction. A small

background survey conducted by the National

Environmental Education and Training Foundation (NEETF) in the preparation of its 2001

report "Standardizing Excellence: Working with

Smaller Businesses to Implement Environmental

Management Systems" found that the top five

factors likely to drive EMS adoption in smaller

enterprises were

1. business benefits of an EMS

2. tax breaks for EMS implementation

3. customer EMS purchasing requirements 

for suppliers

4. insurance benefits of an EMS

5. a performance-based regulatory system.

In heavily regulated sectors, an EMS may

be a way to demonstrate to regulators, lenders,

insurers and buyers that a company is managed

5. DRIVERS AND BARRIERS TO EMS ADOPTION BY

SMALL AND MEDIUM-SIZE ENTERPRISES

in an environmentally responsible way. The

Canadian Federation of Independent Business

(CFIB) survey of SMEs revealed that respondents in the most regulated industries—that is,

those in the primary and agricultural sectors—

were more likely to adopt a formal environmental management system. Businesses in these

sectors were also subject to higher levels of customer requests for EMSs (CFIB 2001).

Driver - Customer Requirements 

For a small and medium-size business, one tangible value in creating and implementing an

EMS is that such a step will meet the requirements of larger customers, or dominant buyers.

Large multinational companies are increasingly

requiring their suppliers to adopt environmental

management systems—a development that

directly affects SMEs. By choosing not to do

business with firms that do not adhere to their

environmental policies, large multinational companies are able to greatly influence the environmental impacts of their smaller suppliers and

distributors. DaimlerChrysler, Ford, General

Motors and Sony, for example, now require ISO

14001 certification of their primary and secondary suppliers. Large companies impose these

requirements for a variety of reasons. Among

them are reduced risk, new European Union

regulations restricting substances in consumer

products, direct financial savings, improved

relations with their customers or regulators and

recognition of responsibility for their environmental impacts.

An example of the effect large corporations can have on their supply chain is illustrated by the Environmental Performance

Agreement between the Canadian Automotive

Parts Manufacturers’ Association (APMA), Environment Canada Ontario Region and Industry

Canada. The agreement, entered into in 2002,

committed participating APMA member companies to be ISO 14001–registered by December

2003 and to take action to reduce emissions of

volatile organic compounds, carbon dioxide and

other substances. APMA members collectively

account for over 90 percent of the $35 billion

automotive parts industry production in Canada.

This agreement was a response to the supply chain

requirements of DaimlerChrysler, Ford Motor

Company and General Motors. Specific targets

and timelines for this initiative are an aggregate

The owner of the

business must believe

that the EMS will

create real tangible

value for the business.
16 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

reduction of 20 percent in VOCs and 3 percent

in carbon dioxide and CEPA toxic substance

substances (where applicable) by 2007.7

A recent pilot project by the World Environment Center (WEC) illustrates this trend. The

WEC is a not-for-profit organization composed

of many large multinational corporations. The

Center’s Supply Chain Management Partnership

promotes the adoption of improved environmental management techiniques and cleaner

production programs among companies that

supply WEC member companies. The WEC is

implementing pilot projects with multinationals

and a select number of their suppliers in Mexico,

Brazil and China (where the project is in the

planning stage). In Mexico, the project involves

Janssen-Cilag, an operating subsidiary of Johnson & Johnson that produces drugs for clients

around the world, and Alcoa Fujikur, whose

lines of business include automotive and electronic distribution systems and fiber-optic cable.

Driver - Trade Association Requirements 

Some trade associations require their members

to have an environmental management system

in place or to adhere to environmental codes of

conduct. For example, national chemical associations in 52 countries run Responsible Care®

programs. Under Responsible Care, member

companies must commit to adopting a set of

guiding principles, codes, guidelines and checklists on health, safety and environmental matters,

and to developing indicators and verification

procedures. They must communicate their "good

faith efforts" to implement the codes to employees and stakeholders.8

Mexico’s National Association of the

Chemical Industry (Asociacion Nacional de la

Industria Quimica—ANIQ) was the first association to design its Responsible Care program as

an environmental health and safety management

system (Sistema de Administracion de R e s p o n sabilidad Integral—SARI). It incorporates e l e m e n t s

of ISO 14001 and fulfills other requirements of

different known management systems related to

environmental, health and safety i s s u e s . A d o p t i o n

of the Responsible Care program is a condition

for becoming a member of ANIQ. Members must

commit themselves is to actively participating in

assistance activities designed to support the

Responsible Care program in member SMEs. 

Responsible Care had a strong impact on

the decision by the National Association of

Chemical Distributors (NACD) to develop an

environmental code of its own (the NACD has

members in Canada and the United States, and

many of its members are small businesses). The

NACD code is based on Responsible Care, but

is stronger in several respects; it requires thirdparty verification of members’ performance, as

well as health, safety, and security, and has a

history of suspending and terminating members

for noncompliance (Nash 2000). 

The Environmental Commitment and

Responsibility program of the Canadian Electricity Association (CEA), which counts small and

medium-size businesses among its members,

stipulates that adoption of an ISO 14001–consistent EMS is a condition of membership.

Under the Environmental Commitment and

Responsibility program, a verification team visits

a selected number of utilities each year to determine whether the EMS implemented satisfies

the program’s requirements.

For SMEs, market forces are particularly

important. This is especially true in Mexico,

which has a large, informal economy and whose

smaller businesses may be subject to fewer regulatory pressures. A recent Inter-American

Development Bank study of ISO 9000, and to a

lesser degree ISO 14001, in certain areas of

Latin America, including Nuevo León in Mexico,

found that a key determinant of the quality of

the environmental management system was the

extent to which management demanded the

system (IADB 2004). However, despite these

market forces, for most SMEs the barriers to

EMS adoption outweigh the drivers. 

Barriers to EMS Adoption 

Barriers are factors that hamper and can even

bring to an end the design, implementation and

operation of an environmental management system. Even when driving forces exist, SMEs may

face imposing barriers when designing and

implementing an EMS that larger companies are

less likely to face. A Lack of knowledge about

and awareness of environmental management

The Importance of the Business Owner

For small and medium-size enterprises, a central factor in the implementation of an environmental management system is the

leadership of the top manager in pushing for

continual improvement. Observers have

noted that a commitment to achieving environmental improvements is a far bigger factor

in achieving environment results than merely

having an EMS in place; an EMS just makes a

company be able to achieve these improvements. In fact, a Canadian Federation of Independent Business (CFIB) survey found that

for 87 percent of respondents the personal

views of owners were the primary motivation

for improved environmental performance

(CFIB 2001).

The Guadalajara Environmental Management Pilot (GEMP) and Proyecto Administración Ambiental Monterrey (PAAM) studies

highlight the importance of manager support

for employee involvement in the EMS process.

Those managers who enthusiastically adopted

EMS concepts and who worked with their

employees achieved successful EMS implementation during the study time period,

whereas those managers who did not with

their employees failed. A manager who sees

an economic benefit in EMS implementation

and actively supports its design and development is a critical factor in EMS implementation

(Lexington Group 2002).

Mexico’s National Association of the Chemical Industry (Asociación Nacional de

la Industria Química—ANIQ) was the first association to design its Responsible

Care program as an environmental health and safety management system

(Sistema de Administración de Responsabilidad Integral—SARI).

7. B. Brad Cummings, manager, Pollution Prevention and

Innovative Technologies, Environment Canada Ontario Region, 

e-mail message to Tim Whitehouse, CEC, January 28, 2005.

8. See <http://www.responsiblecare.org>.
17 A N O R T H A M E R I C A N P E R S P E C T I V E

systems are big barriers to their implementation. A 2001 Canadian Federation of Independent Businesses survey found that nearly

three-quarters of the 4,322 respondents to an

environmental survey of its members were not

aware of the ISO 14000 series (CFIB 2001).

About half the federation members have fewer

than five employees. 

Studies and academic articles also generally note that SMEs are less likely to implement

EMSs, because they are largely occupied with

the day-to-day concerns of keeping their businesses viable and retaining existing customers.

When compared with larger businesses that are

not a subsidiary of a multinational, SMEs generally do not have dominant market positions;

they have less well-defined management structures; they have no support from a parent company; they generate less environmental data;

they have less environmental expertise and

fewer financial and technical resources available

to pursue environmental management; and they

tend to have less interaction with regulatory

agencies (Hillary 1999; CFIB 2001;Coglianese

and Nash 2002).

Several efforts have been made to identify

existing barriers to EMS adoption in both the

United States and Europe. In the United States,

the National Environmental Education and Training Foundation (NEETF) identified some of these

barriers in its report Standardizing Excellence:

Working with Smaller Businesses to I m p l e m e n t

Environmental Management Systems ( N E E T F

2001). The report, developed by means of a

grant from the US Environmental Protection

Agency, grew out of the findings of workshops

held for government and private sector participants who identified practical and effective ways

to promote and design EMSs and to help S M E s

implement them (NEETF 2001, 10). These b a r r i e r s

fall into three categories: motivation, r e s o u r c e

and implementation issues (see box).

In Europe, a 1999 analysis of 33 studies

published between 1994 and 1999 found that

in small and medium-size enterprises "internal

barriers to EMS adoption are more important

than external ones" (Hillary 1999) The barriers

identified in that analysis are closely related to

the barriers listed by NEETF (see sidebar). The

analysis does mention two types of barriers

worth highlighting. One is that EMS implementation is "an interrupted and interruptible

process in SMEs," and the other is "the lack of

sector specific guidance and material tailored to

different sizes of the firms" (Hillary 1999).

The European analysis also raised the issue

of the cost of certification, which echoes the

concerns raised by NORMAPME about the high

cost of ISO certification. Because small firms

generally do not have in-house expertise, they

usually need to hire consultants to help them

design, implement and verify the EMS and

auditors to certify the EMS, costs which larger

firms can more easily handle.

The US NDEMS study noted that many

firms were not measuring or monitoring the

EMS-related aspects of their operations as

actively as they should. Only 27 of the 83 companies studied actually quantified data for environmental performance, and only 32 of 83

quantified the financial benefits. The rest relied

more on a qualitative assessment, which can be

attributed to a failure to establish clear objectives in the EMS design (NDEMS 2003).

Within North America, government-supported programs are available to help SMEs

improve their environmental performance.

Included as part of these programs are government efforts to encourage SMEs to design and

implement EMSs.

Keeping the Costs Down

Here are two examples of the many efforts

being made to address the ISO certification

costs that SMEs may face. 

ENVIROREADY

EnviroReady, launched from Canada with

government and private sector support, is

positioned between self-declaration and third

party certification. Under this process, the

company signs a self-declaration of conformance with EMS requirements. This documentation is then examined by a professional

accountant for evidence that the client’s EMS

meets or exceeds ISO 14001 certification. If

so, the business is issued an EnviroReady

Report <http://www.14000registry.com>.

THE HACKEFORS MODEL

The Hackefors Model was developed to

implement group ISO 14001 certification in

Sweden. Originally, the network consisted of

26 SMEs in the Hackefors Industrial Park outside the city of Linköping, Sweden.

Established in 1995, the group was by 1999

certified under ISO 14001 through the application of group certification, although each

individual enterprise has its own EMS. By

2002, 24 networks and over 450 SMEs were

using the model to achieve ISO 14001 group

certification. Each network has a central coordinator, a steering committee and an EMS

group. These networks have helped to significantly lower the costs of EMS design and

implementation and overcome the size and

resource issues faced by SMEs.

MOTIVATION

• Lack of customer requirements or demand to

have an environmental management 

system

• Misconception that environmental issues are a

low organizational priority or are believed to be

under control

• Belief that an EMS is not important or relevant to

the business or capable of adding to the bottom

line

• Lack of public or nongovernmental organization

pressure to implement an EMS

• Belief that an EMS is the current management

"flavor of the month"

• Belief that an EMS is not widely accepted or used

in an industrial sector or geographic area

RESOURCE ISSUES

• Concern about the cost and time needed to

establish an EMS

• Concern about the operational management

costs after implementation

• Perception that an EMS is complicated and 

unattainable

IMPLEMENTATION CONCERNS

• Fear of discovering noncompliance with regulations or permits

• Fear of discovering or uncovering internal p r o blems within the organization (staff i s s u e s , p r o c e s s

issues, company policies, etc.).

Source: NEETF 2001.

Barriers to EMS Implementation
18 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

D

omestic policies and programs that disseminate information, advice and technical

assistance tools on environmental management

systems are important ways of encouraging the

adoption of those systems by small and medium-size enterprises. Technical assistance tools

can help address the environmental issues identified during EMS implementation.

Technical assistance programs for SMEs

can be found in Canada, Mexico and the United

States. Environmental management systems do

not provide an organization with explicit tools

on how to manage waste, prevent discharges or

reduce air emissions, therefore, technical assistance programs can help to address the technical shortcomings of smaller businesses and

respond to the specific needs of a particular

industrial sector. Outreach programs and technical assistance tools tend to be most successful

when they are developed and delivered at the

regional level and tailored to the specific needs

of businesses.

Technical Assistance in Canada

Environmental Canada, Industry Canada and the

provincial and territorial governments have programs designed to improve the environmental

performance of SMEs (see Table 6.1). These

programs are largely developed to support non

regulatory pollution prevention initiatives targeting SMEs (Environment Canada 2003). 

Programs such as the Eco-Efficiency Partnership in British Columbia <h t t p : / / w w w . s c b c .

o r g / e e p>, the Eco-Efficiency Centre in Nova

Scotia <h t t p : / / w w w . m g m t . d a l . c a / s r e s / e c o %

2 D b u r n s i d e /> and the EnviroClub of Quebec

<w w w . e n v i r o c l u b . c a / e n / c o n t a c t> exemplify the

general approach to improving the environmental performance of SMEs in Canada. These programs are supported by federal, provincial and

corporate sources. The program in British

Columbia provides financial assistance for an

environmental audit to identify potential efficiency gains. The audit is followed by a report developing site-specific options and a business plan

detailing the costs and benefits of implementation. In addition to performing environmental

reviews, the Eco-Efficiency Centre in Nova Scotia and the EnviroClub in Quebec offer tools,

technical assistance and guidance on "best practices" within an industry and encourage environmental cooperation among businesses. 

One example of the type of support these

partnerships can bring is Bain Ultra, located

near Quebec City. Bain Ultra, which has 225

employees, produces baths, hot tubs and shower cases. With the assistance of EnviroClub, the

company identified the significant environmental aspects of its business and developed a plan

to implement an environmental management

system so that it could achieve its ISO 14001

certification by 2006. This exercise allowed the

company to target several measures, easily

implemented that could improve the company’s

environmental performance: recuperating polystyrene scraps; improving the pulverization

process for manufacturing baths and showers;

changing the pulverized resin for one with a 7

percent lower styrene content; and reducing

acetone emissions by 30 percent. These measures, which will be carried out during 2005, are

projected to save the company over C$300,000

a year.9

6. TECHNICAL ASSISTANCE AND OUTREACH

9. F. Huppé, acting head, Toxic Substances and Prevention,

Environment Canada, e-mail message to Tim Whitehouse, CEC,

February 10, 2005.
19 A N O R T H A M E R I C A N P E R S P E C T I V E

Table 6.1 Sample Technical Assistance Programs in Canada

Program Description

Operates an eco-efficiency web site offering tools and

best practices. Sponsors, with Natural Resources Canada

and the National Research Council, free two-day workshops for SMEs on eco-efficiency (which includes EMSs).

Involved in the Environmental Supply Chain Management

Pilot Project, a voluntary initiative aimed at reducing

greenhouse gas emissions from SMEs in the Canadian

manufacturing sector.

Directed at building the capacity of Canadian SMEs.

Offers assistance for improving resource efficiency.

Produces "Design for Environment" online resources to

facilitate the integration of environmental considerations

into the product and process designs of SMEs.

Provides one-stop pollution prevention technical assistance for SME manufacturers in the Greater Toronto Area

(GTA), and a 50% cost-share funding incentive. The GTA

is Canada’s largest and busiest urban area, and includes a

number of diverse manufacturing SMEs that generate

smog, greenhouse gases, and toxic releases to the air and

sewers, and hazardous wastes.

Designed to assist SMEs in preventing spills to groundwater, surface water and sewers in the Regional Municipality

of Waterloo (Ontario). Grants are provided to local SMEs

to cost share facility a review and assessment, and to

implement best management practices, including EMSs.

This includes an inventory of chemical substances; identifies risk areas and potential for spills; reviews pollution

prevention plans; and identifies opportunities for SMEs to

improve environmental performance.

A pilot program to reduce criteria air pollutants generated

by SME industrial manufacturing operations in Southwest

Ontario. The goal is to identify opportunities for SMEs to

reduce emissions of key criteria air pollutants (nitrogen

oxides, sulphur dioxide, particlulate matter and volatile

organic compounds), to improve their environmental performance and economic competitiveness.

The three (3) CETACs provide business services to

Canadian entrepreneurs, start-up companies and SMEs to

support the development, demonstration, verification and

deployment of innovative environmental technologies.

This is accomplished through the provision of support

services such as general business development counseling,

market analysis, assistance in raising capital, and technical

assistance.

Assists SMEs in Quebec by providing access to expertise

and financing for pollution prevention projects, including

EMSs. Provides workshops and professional consulting

services to members for a fee.

Industry Canada

<http://strategis.ic.gc.ca/epic/

internet/inee-ee.nsf/en/Home>

National Research Council, Industrial

Research Assistance Program 

(NRC-IRAP) <http://dfe-sce.nrccnrc.gc.ca/dfestra/dfestra_e.html>

Toronto Region Sustainability

Program (TRSP)

<h t t p : / / w w w . o c e t a . o n . c a / t o r o n t o . h t m>

Business Water Quslity Program

(BWQP)

<h t t p : / / w w w . o c e t a . o n . c a / b w q p . h t m>

Business Air Quality Program (BAQP)

Canadian Environmental Technology

Advancement Centres (CETACs)

<http://www.oceta.on.ca>

<http://www.cetacwest.com>

<http://www.enviroaccess.ca>

Enviroclub, Quebec

<http://www.ec.gc.ca/cppic/Search

/en/SearchDetail.cfm?ID=2346&xTa

ble=nopp_tbl>
20 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

Technical Assistance in Mexico

Among the services available to help Mexican

SMEs with the technical issues associated with

environmental management are the Enterprise

Committee for Sustainable Development and

the Mexican Center for Cleaner Production.

Technical assistance is particularly important in Mexico, where SMEs are likely to face

higher costs than those in Canada and the United States and greater technical hurdles and

infrastructure difficulties in implementing and

certifying to the ISO 14001 standard (Pacific

Institute for Studies in Development, Environment, and Security 2000). Technical assistance

for small and medium-size businesses taking

steps to prevent pollution and introduce cleaner

production techniques is an important component of the World Environment Center’s effort

and of the efforts of the sponsors of the

Guadalajara Environmental Management Pilot

(GEMP) and Proyecto Administración Ambiental Monterrey (PAAM) studies (see Chapter 3).

In the Guadalajara project, this support

included assigning a consultant to each SME to

provide implementation assistance as well as a

mentor company to monitor progress (World

Bank 1998). In the World Environment Center

project in Mexico, partners held a workshop on

cleaner production and environmental management training for suppliers and conducted oneday follow-up visits to the suppliers (WEC 2004)

Eco-Efficiency Partnership (EEP),

British Columbia

<http://www.c2p2online.com/main.

php3?doc_id=381§ion=154>

Eco-Efficiency Centre, Nova Scotia

<http://www.mgmt.dal.ca/sres/

eco-burnside/>

Reference Center for the Life Cycle

Assessment, Interpretation and

Management of Products, Processes

and Services (CIRAIG, 

<h t t p : / / w w w . c o n g r e s b c u . c o m / c i r a i g />

Helps small and medium-size manufacturing enterprises

to find ways to become more competitive, using fewer

resources such as energy, water or materials.

Is a cost-sharing arrangement with participating companies, in which EEP provides matching funds to a company to pay for consultants able to recommend process

improvements that make financial and practical sense.

Helps companies to adopt good environmental practices,

while improving the efficiency of individual companies,

primarily SMEs. Encourages companies to commit to conservation goals and to cooperate and exchange successful

experiences. Also provides information on eco-efficiency,

offers training sessions and workshops and contributes to

education and research. 

Provides tools and training for life cycle management and

assessment. Is a partner in the UN Environment

Program/Society of Environmental Toxicology and

Chemistry Life Cycle Initiative, which is based in academic

institutions in Montreal. 

Commission for Private Sector

Studies in Sustainable Development

(Comisión de Estudios del Sector

Privado para el Desarrollo

Sustentable—cespedes,

<http://www.cce.org.mx/cespedes>

Mexican Center for Cleaner

Production (Centro Mexicano para la

Producción Más Limpia)

<http://www.cmpl.ipn.mx>

Promotes sustainable practices such as eco-efficiency and

social responsibility in Mexico’s industrial sector. Offers

workshops and seminars on sustainable development,

pollution prevention and environmental management 

systems. 

Serves as a vehicle for the UN Industrial Development

Organization (UNIDO) and Mexican National Polytechnic

Institute to implement pollution prevention projects. 

Table 6.2 Sample Technical Assistance Programs in Mexico

Program Description
21 A N O R T H A M E R I C A N P E R S P E C T I V E

Technical Assistance in the United States

In the United States, numerous state and federal agencies, nonprofit organizations and academic institutes offer programs that encourage

EMS research, training and implementation. In

addition, the US EPA has established partnerships with state agencies, universities and other

organizations to maximize resources and support for EMS programs.

The US EPA’s web site at <http://www. epa.

g o v / e m s / i n d e x . h t m> provides access to

research papers, best practices, guidance documents and EMS templates. An example of the

documents available is Environmental Management Systems: An Implementation Guide for

Small and Medium-sized Organizations ( r e i ssued November 2003), providing simple, useful

information and case studies to help small and

medium-size businesses develop EMSs.

US EPA’s Small Business Division serves as

the primary entry point through which small

businesses can access US EPA information. It

also facilitates communications between the

small business community, including national

trade associations, and the US EPA. In 2003, the

US EPA issued its revised "Small Business Strategy" that is designed to bring unity and

improved effectiveness to Agency-wide efforts

to assist small businesses in improving their

environmental performance.

The US EPA Small Business Division has

developed several documents to help small

businesses design and implement an EMS.

These documents include:

■ Practical Guide to Environmental Managem e n t: The Guide describes a common sense

process for improving the small business’s environmental management activities and can be

found at <h t t p : / / w w w . s m a l l b i z - e n v i r o w e b . o r g /

h t m l / p d f / E M_G u i d e 0 9 0 2 . p d f>

■ Documenting Your Environmental Management Plan—A Workbook for Small Business:

This workbook is for small business owners who

worry that what they don’t know can hurt them

and want to move away from "fire fighting" environmental issues. It shows how to get take a

proactive stance without disrupting their day-today business operations. It can be found at

<h t t p : / / w w w . s m a l l b i z -e n v i r o w e b . o r g / h t m l / p d f /

D o c u m e n t i n g_E M P . p d f>

■ A series of environmental best management

practice (BMP) fact sheets for small businesses.

The BMPs cover the following sectors: bakery,

food services, furniture finishing, health care,

hotels, landscaping, machine shops, marinas,

retail stores, and service stations. These fact

sheets were completed in October 2004 and

will be updated periodically to ensure that the

information they contain is useful to the target

sectors. They are designed to be used with the

publications listed above: "Practical Guide . . ."

and the "Documenting . . . Workbook." These

fact sheets can be found at <h t t p : / / w w w . s m a l lb i z - e n v i r o w e b . o r g / p o l l u t i o n / B M P s . h t m> .

There are a wide variety of partnership programs providing technical assistance, training

and tools to help with EMS development. The

National Directory of EMS Technical Assistance

Providers (TAP Directory) provides user friendly

links to a wide variety of EMS assistance r e s o u r c e s

in the 50 states <w w w . e p a . g o v / e m s /i n d e x . h t m>.

Also, the Public Entity EMS Resource Center

(PEER) web site at <w w w . p e e r c e n t e r . n e t />

provides a broad array of information and tools

to help public entities (primarily local governments) understand and adopt environmental

management systems (EMSs) for their operations. The PEER Center is a collaboration

between the office of Water at US EPA and the

Global Environment and Technology Foundation (GETF). In addition, a number of organizations around the country called EMs Local

Resource Centers, or PEER Centers, are reaching out to local governments to help them

adopt EMSs. 

Twenty-four states have developed public

policy–related EMS policies and programs,

internal EMSs or environmental laws that recognize EMSs.1 0 Many of these programs promote

multimedia environmental management,

rewarding companies that achieve superior

environmental performance by providing regulatory incentives and public recognition similar

to US EPA’s National Environmental Performance Track program (see Chapter 7).

Some US states coordinate and share their

experiences (in an unofficial capacity) on EMS

programs through the Multi-State Working

Group on Environmental Performance

(MSWG), which is composed of representatives

of federal and state agencies, businesses, academia and nongovernmental organizations

(NGOs). The organization was created to promote the use of EMSs through public and private policy innovation. The MSWG d e v e l o p s

and provides information on credible and effective environmental management systems and

other public policy tools that can be used in

pursing improved environmental performance

10. These states are Arizona, California, Colorado, Connecticut,

Florida, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maine,

M a s s a c h u s e t t s, Minnesota, New Hampshire, North Carolina, Ohio,

Oregon, Pennsylvania, South Carolina, Texas, Vermont, Virginia,

Washington and Wisconsin.
22 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

and sustainability. For example, the External

Value EMS Voluntary Guidance: Gaining Value

by Addressing Stakeholder Needs (March

2004) offers advice to organizations that wish to

develop an EMS that, in addition to providing

improved internal value, delivers measurable

and reliable value to external audiences, such as

governmental authorities, local communities,

customers and suppliers, environmental groups,

and investors and the financial community,

among others. This Guidance focuses on three

key elements that should be addressed within

an organization’s EMS if it has these external

value aspirations: 

• Achievement and Demonstration of Legal

C o m p l i a n c e ;

• Involvement of External Stakeholders;

• External Communications: Transparency and

R e p o r t i n g .

T h e MSWG is also developing a web-based

news source, library and e-network for EMS

practitioners and leaders. It can be found at:

<h t t p : / / w w w . m s w g . o r g> .

US EPA’s Small Business

Ombudsman (SBO)/Small Business

Division (SBD)

<http://www.epa.gov/sbo> and

<http://www.smallbiz-enviroweb. org/>

US EPA’s Sector Strategies Programs

<h t t p : / / w w w . e p a . g o v / i s p d / p r o g r a m .

h t m l>

Design for the Environment (DfE)

EMS program

<http://www.epa.gov//dfe/pubs/

iems/iems_guide/index.htm>

Serves as the advocate for small businesses and as their

gateway to the Agency. Facilitates communications

between small businesses and EPA to assist in resolving

issues. Works within the Agency to increase their understanding of small businesses in the development and

enforcement of environmental regulations. Most recently

developed a Small Business Strategy and Implementation

Plan to coordinate and unify the more than 100 EPA small

business initiatives. Oversees the State Small Business

Ombudsmen and State Small Assistance Programs that

were established under section 507 of the 1990 Clean Air

Act Amendments. Has produced several tools for small

businesses including: Practical Guide to Environmental

Management for Small Businesses and Documenting

Your Environmental Management Plan—A Workbook for

Small Business (see appendix A for more information).

Works to enhance the environmental performance of 12

manufacturing and service sectors: agribusiness, cement,

colleges and universities, construction, forest products,

iron and steel, metal casting, metal finishing, paint and

coatings, ports, shipbuilding and ship repair, and specialty

batch chemicals. Aims to improve environmental performance through a knowledge-based approach to problem solving and implementation of systematic management of environmental issues. Will produce EMS implementation guidance documents for each of the targeted

sectors

Works in partnership with individual industry sectors to

encourage the incorporation of environmental, health and

safety considerations into the design of processes and

products. For example, works with the Screen Printing

and Graphic Imaging Association (SGIA) International

Partnership to develop an industry-wide EMS that specifically address the environmental health and safety issues

arising from the inks used in screen-printing. The SGIA

developed tools and templates for conducting gap analyses, creating EMS manuals, evaluating processing, and

auditing.

Table 6.3 Sample Technical Assistance Programs in the United States

Program Description
23 A N O R T H A M E R I C A N P E R S P E C T I V E

Manufacturing Extension

Partnerships 

(MEP) <http://www.scitechresources.gov/Results/show_result.

php?rec=2319> and

<http://www.mep.nist.gov/

environment/environment.htm>

Green Suppliers Network

<http://www.epa.gov/p2/programs/

gsn.htm>

US EPA National Environmental

Compliance Assistance

Clearinghouse (Clearinghouse)

<h t t p : / / w w w . e p a . g o v / c l e a r i n g h o u s e>

The Sector Notebook series,

<www.epa.gov/compliance/

sectornotebooks.html>

Compliance Assistance Centers 

<www.assistancecenters.net>

Pollution Prevention Resource

Exchange (P2Rx) <www.p2rx.org>

A nationwide network of nonprofit centers that support

small and medium-size businesses. Centers are located in

all 50 states and linked through the National Institute of

Standards and Technology (NIST) of the US Department

of Commerce. Uses the EMS-based methodology of

"clean manufacturing" to help companies reduce environmental impacts and costs through resource efficiencies

and process optimization. Clean manufacturing focuses

initially on specific processes, but the principal concepts

encourage continuous improvement through systematic

management. MEP program is now working with the US

EPA’s Green Supply Chain program in which major companies help to recruit their SME suppliers for "clean (and

lean) manufacturing" projects.

As an innovative collaboration among industry, US EPA

and 360vu, a provider of technical assistance to US manufacturers through its national network of MEP aims to

work with all levels of the manufacturing supply chain to

achieve environmental and economic benefits. By

employing "lean and clean" methodologies, companies

can learn how to decrease the use of toxic and nonrenewable materials, establish systems to use energy more efficiently, improve the use and selection of more environmentally friendly raw materials, institute work practices to

reduce labor and costs, and promote a culture of greater

employee participation in improvement activities.

Offers a wide variety of public and private sector environmental compliance information. Visit the Clearinghouse’s

collection of links to materials on EMSs at <http://cfpub.

epa. gov/clearinghouse/index.cfm?TopicID=C : 1 0 : 3 0 0 : E M S>

The Sector Notebook series is a unique set of profiles

containing a wealth of sector-specfic environmental information. Unlike many resource materials, which are organized by air, water and land pollutants, the over 35

Notebooks provide a holistic, "whole facility" approach by

integrating manufacturing processes, applicable regulations and other relevant environment information. 

Created through EPA sponsored partnerships with industry,

academic institutions, environmental groups, and other

agencies, help businesses, local governments and federal

agencies understand Federal environmental requirements

and save money through pollution prevention techniques.

Through web sites, telephone assistance lines, fax-back

systems, e-mail discussion groups and more, the Centers

aim to help address real-world issues in language that is

used by the regulated entities.

A consortium of eight regional pollution prevention information centers, funded in part through grants from EPA.

Represents a broad constituency, including state and local

pollution prevention programs, manufacturing extension

partnerships, cooperative extension and nonprofit organizations.
24 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

Within Canada, Mexico and the UnitedStates, the traditional environmental regulatory actions are being carried out in conjunction with non regulatory voluntary programs

designed to provide incentives for greater environmental performance. Each country has programs designed to encourage the use of

environmental management systems; however,

unlike Europe’s Eco-Management and Audit

Scheme, which requires the use of environmental management systems in larger industrial

facilities (see Chapter 2), these efforts are largely

voluntary and incentive-based. 

Both Mexico and the United States have

recognition programs in which the use of an

EMS by a company is one factor the government considers in determining whether to recognize a company as a top environmental

performer. Although no federal incentive programs exists in Canada, the Canadian Environmental Protection Act (CEPA) recognizes the

use of certified environmental management systems to achieve performance requirements and

gives the courts the authority to require a company to become certified in a "recognized" EMS

standard as part of the court-ordered option.

Some Canadian companies have been required

by the courts to develop a certifiable EMS as

part of a sentence.1 1

Incentive Programs and Policies in Mexico

Mexico’s Environmental Auditing Program

(EAP) is based on a voluntary agreement

between the Federal Attorney for Environmental Protection (Profepa) and an organization.

Under the EAP, a plan of action is devised to

recommend preventive and corrective measures related to air, water, soil, solid and hazardous waste, noise, industrial safety and

hygiene, energy, natural resources, environmental risk, environmental management and

any other issue with potentially adverse impacts

on the environment.

Participating organizations are evaluated

by independent auditors accredited by the

Mexican Accreditation Entity, which has an

agreement with Profepa to audit companies

under EAP. Profepa also provides interested

organizations with a guide for performing selfassessments of environmental impact and management in preparation for the environmental

auditing process. Once the audit has been completed, the action plan implemented and all the

preventive and corrective measures have been

taken, organizations receive Profepa’s c e r t i f i c ations of Clean Industry or Environmental Compliance. Organizations that go further to achieve

stronger environmental performance under pollution prevention and eco-efficiency schemes

are granted the recognition of Environmental

Excellence. Upon receiving the certification or

recognition, organizations can use Profepa’s

performance seals to promote their public

image (see sidebar). 

Profepa acknowledges that organizations

that have an EMS in use may reach and maintain environmental compliance more easily.

However, while having an EMS in place is a

requirement for achieving the Recognition of

Environmental Excellence, it is not mandatory

for the Clean Industry or Environmental Compliance Certifications .

The performance seals are registered at

the Mexican Institute of Industrial Property. 1 2

Once granted to an organization, a seal can be

displayed at its facilities, in its publicity and with

its products and services. The right to use the

seals is valid for the period of time specified in

the agreement, but that period cannot exceed

two years.

In over 12 years of operation, the program

has certified 1,623 organizations; 1,454 organizations currently have active certification. Most

of the organizations certified are large private

and public companies located in large and

medium-size cities such as Mexico City, Monterrey, Guadalajara, Tijuana and Puebla. 

Incentive Programs and Policies in the United

S tat e s

US EPA’s National Environmental Performance

Track program recognizes top environmental

performers among participating public or private US facilities of all types and sizes whether

public or private (US EPA 2004a). To be recognized under Performance Track, facilities must

h a v e :

7. INCENTIVE PROGRAMS AND POLICIES

Seals of Performance Granted by the

Mexican Environmental Audit Pr o g r a m

CLEAN INDUSTRY SEAL: Granted to manufacturing companies that have

fully complied with the plan of

action resulting from the environmental audit (which

involves, among other things,

complying with current environmental regulations).

ENVIRONMENTAL COMPLIANCE SEAL:

Granted to organizations that

do not use industrial processes

in their operation, but have

complied with the recommended

plan of action. 

ENVIRONMENTAL EXCELLENCE SEAL:

Granted to organizations, recognized by an "excellence

group," that have engaged in

self-designed initiatives

directed toward preventing

pollution, seeking community outreach,

developing suppliers, solving local environmental problems and participating in pollution reversion programs, among other measures. To obtain the seal, organizations must

present documented and operational proof

of environmental compliance and the availability of an environmental management 

system.

11. Notable cases include Prospec Chemicals (1996), Coretec

(1998) and Alberta Waste Management Facility (1999).

12. The misuse of the seals is subject to sanctions and fines under

the Industrial Property Law and its regulation.
25 A N O R T H A M E R I C A N P E R S P E C T I V E

• an environmental management system in

place for at least one full cycle that has been

assessed by an independent party 

• a history of sustained regulatory compliance

and a commitment to continued compliance

• past environmental achievement and a commitment to continuous environmental improvement 

• community outreach procedures in place.

Organizations accepted into the program receive

special benefits, such as: low priority for routine

federal inspections; special regulatory and

administrative incentives, such as preference to

Performance Track Members in developing

flexible Title V air permits and reduced reporting

frequency for Performance Track facilities that

are minor or synthetic minor sources subject to

Maximum Achievable Control Technology

(MACT) standards; and more flexible requirements for large hazardous waste generators In

addition, EPA informs elected officials of the

Performance Track members in their districts.

Performance Track has a special program

to promote participation by small facilities (that

is, any facility with less than 50 persons), including those that are part of a larger corporate entity. For small facilities, the US EPA recognizes

that the scope, level and formality of the EMS

will depend on the nature, size and complexity

of the facility and that the EMS will not require

the same level of detail and verification procedures as the EMSs in place in larger facilities. 

The US EPA issued a formal EMS Policy in

May 2002. It calls for promoting the widespread

development and implementation of EMSs

based on the plan-do-check-act ISO 14001

framework. The EMS Policy provides that, while

EMSs do not replace the need for regulatory

and enforcement programs, they can complement them. Having an EMS in place can indicate to the EPA an opportunity to streamline

regulations and consider the company to be in

compliance assistance, monitoring, and enforcement. In support of this Policy, the EPA has

developed EMS programs, training, tools and

partnerships to help achieve the agency’s goals

of improving compliance, preventing pollution

and reducing costs. In April 2004, the EPA

issued the Strategy for Determining the Role of

Environmental Management Systems in Regulatory Programs (US EPA 2004b). The Strategy

was developed in response to the increasing

interest of stakeholders in the US EPA’s use of

EMSs in permits, rules and enforcement actions.

The EMS Strategy encourages carefully

designed experimentation to determine whether

EPA and the states, by considering EMSs in permits and regulations, can achieve better environmental results at less cost, improve compliance,

target resources more effectively, and enhance

public involvement. It states that although EMSs

cannot guarantee any specific level of performance, EPA believes that, when properly implemented, EMSs can help facilities achieve

significantly improved environmental results and

other positive benefits. The US EPA is using the

Strategy to explore ing the possible benefits of

incorporating EMS options into the US regulatory structure, but it does not intend to mandate

the use of EMSs (Bergeson 2004). 

In 1995, the US EPA issued a policy called

Incentives for Self-Policing, Discovery, Disclosure, Correction and Prevention of Violations

(USEPA Audit Policy). It was revised in 2000.

Under this policy, penalties may be reduced or

eliminated for facilities that discover violations

through self-auditing or under environmental

management systems; and that self-disclose and

correct the violations promptly and take measures

to prevent recurrence and promptly comply with

other requirements set under the policy.1 3

The US EPA’s Small Business Compliance

Policy promotes environmental compliance

among small businesses with fewer than 100

employees by providing incentives to discover

and correct environmental problems. The

agency offers to eliminate or significantly reduce

penalties for small businesses that voluntarily

discover violations of environmental law and

promptly disclose and correct them."1 4

In addition to establishing programs that

encourage companies to systematically manage

environmental performance, in 2003 the US EPA

joined EMSs with enforcement efforts by issuing

its Guidance on the Use of Environmental Management Systems (EMSs) in Enforcement Settlements as Injunctive Relief and Supplemental

Environmental Projects (June 12, 2003). The

Guidance reiterates EPA’s compliance and

enforcement office’s support for the use of EMSs,

by organizations of all sizes and types. The EMSs

can be used as a tool to maintain compliance,

achieve results beyond compliance, and minimize

environmental impacts in non-regulated areas.

More information can be found at: <h t t p : / /

w w w . e p a . g o v / c o m p l i a n c e / r e s o u r c e s / p o l i c i e s /

i n c e n t i v e s / e m s / e m s s e t t l e m e n t g u i d a n c e . p d f> .

The directive also explains how the EPA

will encourage the use of compliance-focused

EMSs (CFEMS) as injunctive relief in enforcement

settlements where it is necessary to address the

root causes of the violations. More information

on Compliance-Focused Environmental ManIdeal Jacobs Corporation

The Ideal Jacobs Corporation of Maplewood,

New Jersey, is an ISO 9002/14001 registered

facility that specializes in printing and the fabrication of plastic and metal parts. 

OVERVIEW

Ideal Jacobs is one of the smallest facilities in

US EPA's National Environmental Performance

Track program, and yet it boasts an efficient

environmental management system. The EMS

is used to track and eliminate unnecessary

production waste as well as to gain more 

control over the facility's budget. By gauging

expenses and implementing programs to

reduce those expenses, the company is initiating changes that ultimately contribute to e n v ironmental performance and cost effectiven e s s. Ideal Jacobs's EMS is also used to track

the business aspect of production to observe

investments and their subsequent effect on

profits. The company's growth of 10 percent

in 2000 reinforced the notion that environ -

mental performance and cost-effectiveness

can progress together. 

BENEFITS

For this company, the direct results of its EMS

were, in 2002, near-zero generation of h a zardous wastes and compliance with the thresho l d sfor all other levels of emissions to the

extent that the company did not need permits

of any kind. Cost savings in 2002 attributed

to the EMS were approximately $25,000.

Ideal estimated that the $20,000 cost it

incurred to implement the EMS at its facility

was captured in this one-year cost savings.

Source: US Environmental Protection Agency,

<h t t p : / / w w w . e p a . g o v / e m s / s t u d i e s / j a c o b s . h t m>

13. See <http://www.epa.gov/compliance/incentives/auditing/

auditpolicy.html>

14. See <h t t p : / / w w w . e p a . g o v / c o m p l i a n c e / i n c e n t i v e s / s m a l l b u s i n e s s>
26 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

agement System (CFEMS) - Enforcement

Agreement Guidance can be found at:

<h t t p : / / w w w . e p a . g o v / c o m p l i a n c e / r e s o u r c e s /

p u b l i c a t i o n s / i n c e n t i v e s / e m s / e m s 1 2 e l e m r . p d f> .

In addition, the directive explains when

EMSs that meet the criteria in the Supplemental

Environmental Project (SEP) Policy, according to

their state and local governments, will be eligible for SEP penalty mitigation credit. More

information can be found at:

<h t t p : / / c f p u b . e p a . g o v / c o m p l i a n c e / r e s o u r c e s /

p o l i c i e s / c i v i l / s e p s /> .

Finally, the directive describes how persons who discover, correct, and disclose violations discovered through EMSs can be eligible

for penalty mitigation under EPA’s Audit Policy

and statute-specific penalty policies.

Some US states are also developing rules

and permits linked to EMSs. These state programs provide incentives for companies that

implement EMSs and engage stakeholders. EMS

concepts have been integrated as well into several federal and state pollution prevention and

risk reduction programs. Organizations that

exceed threshold quantities of chemical use or

hazardous waste generation are required to

evaluate risks and then implement programs and

systems to minimize and mitigate potential

releases to the environment. Components of

these programs typically include planning,

reporting, auditing and stakeholder involvement. In particular, Section 112(r) of the Clean

Air Act establishes a federal focus on the prevention of chemical accidents. The objective of

section 112(r) is to prevent serious chemical

accidents that have the potential to affect public

health and the environment. Under these

requirements, industry has the obligation to prevent accidents, operate safely, and manage hazardous chemicals in a safe and responsible way.

Voluntary government incentives programs

are relatively new in North America. While having an environmental management system is a

required component of EPA’s Performance Track

Program and Profepa’s Environmental Excellence Seal, time will reveal the extent to which

SMEs participate in these programs and whether

they affect EMS use over the longer term.
27 A N O R T H A M E R I C A N P E R S P E C T I V E

G

overnments are promoting EMSs as one of

a variety of tools available to help SMEs

improve their environmental performance and

their bottom line. The experiences in North

America suggest some "lessons learned" that

can be valuable in helping to shape any future

government or private sector initiatives designed

to promote the use of EMSs by small and mediumsize enterprises: 

■ A business case must exist. Governments

are most successful in recruiting SMEs for voluntary environmental programs when the business case for environmental management is

clearly demonstrated.

■ Business requirements are vital. The power

of the suply chain, business contracts and

industrial associations are significant for many

S M E s .

■ A tailored outreach can be helpful. Outreach

efforts that are narrowly tailored to the business

sector, size and location of the SME will be far

more successful than generic outreach efforts.

Generic EMS toolkits can be time and resource

consuming when applied to the different organizational structures and specific sectors of

SMEs. 

■ The right partners are essential. When government programs have involved non-governmental organizations or SMEs themselves, as

partners, the likelihood of success has been

greater. The governments of the three countries

should promote forums in which companies can

present not only the results of their EMSs, but

also the process used to implement and develop them.

■ A key factor is the knowledge and attitude of

the owners. For small and micro-enterprises,

the knowledge and attitude of the owner/operator are often critical factors .

■ An EMS in and of itself does not mean better

environmental performance. EMSs are flexible ,

and so their impact depends on how they are

implemented and integrated. EMSs do not necessarily lead to improved performance, unless

pursuing and measuring environmental

improvement are integral to the EMS.

■ Regulatory compliance pressure is a motivator of environmental performance. In certain

sectors and in certain parts of North America,

the pressures of regulatory compliance can be

an important motivator in prompting the search

for least-cost solutions. EMSs can be associated

with the current requirements of environmental

a g e n c i e s .

An EMS can provide the methodology a company needs to identify and implement ways of

making environmental improvements. For small

and medium-size businesses that are not part of

a larger corporation, sector-specific technical

assistance and outreach efforts are often critical

in providing the expertise that may not exist

within a company. Because very little empirical

research exists on the extent to which successful EMS practices are being used by SMEs, continued research by academic institutions and

government agencies is necessary. This

research could help shed light on how and

under what circumstances EMSs can improve

environmental performance in small and medium-size enterprises and the success of assistance and outreach efforts. Specific areas of

further research could include the following

q u e s t i o n s :

■ Will government incentives for EMS adoption and use—such as technical assistance,

public recognition and regulatory flexibility—

increase the use of EMSs over the longer-term?

■ If so, how will these incentive programs

affect environmental performance over the

longer term?

■ How will the environmental requirements of

large customers and trade associations affect

the environmental performance of suppliers

over the long term?

■ How do successful EMS adopters overcome

implementation problems? And what do their

experiences offer subsequent adapters in the

way of models?

Research that offers insights into environmental

performance in specific sectors and specific

geographic regions will be particularly important in driving future policy decisions of governments on the promotion of environmental

management systems. As this type of research

develops, continued cooperation between the

three countries could occur in several areas.

The goal of this cooperation should be to

improve the delivery of sector-specific information and technical assistance to SMEs. Such an

improvement could entail

8. FUTURE DIRECTIONS
28 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

■ sharing sector-specific EMS implementation

tools and lessons learned from specific sector

a c t i v i t i e s

■ exploring additional ways to support efforts

to green the supply chain

■ continuing to look for and share success stories, particularly as they relate to new and

emerging programs such as USEPA’s Performance Track program and Mexico’s Environmental Auditing Program

■ promoting greater interaction between local,

state and provincial governments on the success of their programs. 

This type of cooperation could be particularly

beneficial to Mexico. Efforts to green the supply

chain by large multinationals have great potential to improve the environmental performance

of smaller suppliers in Mexico. Also, the technical assistance and outreach efforts in the United

States and Canada could provide useful lessons

for Mexico as it develops its own internal capacity to provide this type of support. In addition,

the networks and information sharing that have

developed in the United States as a result of the

work of the Multi-State Working Group and

other organizations can provide valuable lessons for Mexico’s states as they take on more

environmental responsibility. 

While cooperation could be particularly

beneficial to Mexico, it could also be of benefit

to all of those promoting environmental management systems in Canada, Mexico and the

United States. By sharing experiences and success stories, particularly as they relate to specific

supply chains and sectors of the economy, governments and technical assistance providers can

improve their delivery of services to small and

medium-size businesses by building on existing

lessons learned.
29 A N O R T H A M E R I C A N P E R S P E C T I V E

Appendix A

Useful Web Sites in Addition to References

P r o v i d e d

EMAS Toolkit for Small Organisations

<h t t p : / / w w w . i n e m . o r g / e m a s - t o o l k i t> .

This web site has information on how to create

an environmental management system based

on the "Plan, Do,Check, Act" model. It also

contains case studies.

Energy Star Small Business <h t t p : / / w w w . e n e r g y

s t a r .g o v / s m a l l b i z>. ENERGY STAR is a US government-backed program helping businesses

and individuals protect the environment

through superior energy efficiency. This web

site has information and materials designed

specifically for small business. English and

Spanish versions available.

MEDS—Manufacturing Efficiency Decision

Support Tool <h t t p : / / m e d s . m m t c . o r g />. This

web site provides users with information on the

performance, cost, and energy and environmental implications of alternative manufacturing

t e c h n o l o g i e s ,

MAP—Manufacturing Assessment Planner

Toolkit <h t t p : / / m a p . m m t c . o r g /> . The Manufacturing Assessment Planner (MAP) Toolkit is

designed to aid MEP field agents in performing

low-cost assessments. The planner provides the

necessary steps and procedures to conduct an

eight-hour, integrated energy, environment,

and manufacturing efficiency assessment for a

small or midsized facility.

Ontario Clean Air Alliance—Emissions Calculator, <h t t p : / / w w w . e l e c t r i c i t y c h o i c e s . o r g>. This

web site allows users to calculate air quality

impacts and provides information on green

energy suppliers.

P2 World Information Network

<h t t p : / / w w w . p 2 w i n . o r g> . A global network

bringing together pollution prevention roundtables and cleaner production networks to

strengthen partnerships, encourage innovation

and take collective action.

Environmental Management Accounting (EMA)

<h t t p : / / w w w . n e w m o a . o r g / p r e v e n t i o n / t o p

i c h u b / t o c . c f m ? h u b=1 0 5 & s u b s e c=7 & n a v=7> .

EMA is the identification, collection, estimation,

analysis, internal reporting, and use of materials

and energy flow information, environmental cost

information, and other cost information for both

conventional and environmental decision-making 

within an organization. For companies that have

the goals of saving money, especially environmental costs, and reducing environmental

impacts, EMA provides essential information for

meeting those goals

Green Purchasing <h t t p : / / w w w . p 2 r i c . o r g / T o p i c

H u b s / t o c . c f m ? h u b=1 3 & s u b s e c=7 & n a v=7> .

Green purchasing is a consideration of supply

chain management and is also known as environmentally preferred purchasing (EPP), green

procurement, affirmative procurement, ecoprocurement, and environmentally responsible

purchasing. Green purchasing attempts to identify and reduce environmental impact and to

maximize resource efficiency. 

Lean Manufacturing <h t t p : / / w w w . z e r o w a s t e

n e t w o r k . o r g / h u b / p 2 r x - m o d / s u b s e c t i o n . c f m ?

h u b=1 9 & s u b s e c=1 & n a v=1>. Lean Manufacturing is a systematic approach to identifying and

eliminating waste (non-value-added activities)

through continuous improvement by flowing

the product at the pull of the customer in pursuit of perfection

Small Business Environmental Homepage

<http:// www.smallbiz-enviroweb.org>. This

web site, funded by US EPA and maintained by

the private sector, contains information on compliance assistance, pollution prevention, industry sectors, performance measurements, and

awards and grants for small businesses in the

United States Examples of material on this web

site include:

Practical Guide to Environmental Management

<h t t p : / / w w w . s m a l l b i z - e n v i r o w e b . o r g / h t m l /

p d f / E M_G u i d e 0 9 0 2 . p d f>

Documenting Your Environmental Management

Plan—A Workbook for Small Business, (September 2003) is a workbook for small business

owners who worry that what they don’t know

can hurt them and want to move away from

"fire fighting" environmental issues. It shows

how to get a proactive stance without disrupting their day-to-day business operations. 

<http://www.smallbiz-enviroweb.org/html/

pdf/ Documenting_EMP.pdf>.

Environmental Best Management Practices for

Small Businesses <http://www. smallbiz-enviroweb.

org/pollution/ B M P s . h t m l> .

Best Management Practices (BMPs) for the following sectors: bakery, food services, furniture

finishing, health care, hotel, landscaping,

machine shop, marina, retail store, service station (these fact sheets were completed in October 2004 and are designed to be used with the
30 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

publications listed above: "Practical Guide . . ."

and the "Documenting . . . Workbook

<h t t p : / / w w w . s m a l l b i z - e n v i r o w e b . o r g / s b a /

k e y_s m a l l b i z_p u b l i c a t i o n s . h t ml > .

US Department of Energy—Industrial Assessment Centers Program

<h t t p : / / w w w . o i t . d o e . g o v / i a c>. The Industrial

Assessment Centers (IACs) provide eligible

small- and medium-sized manufacturers with

no-cost energy assessments. Teams composed

mainly of engineering faculty and students from

the centers, located at 26 universities around

the country, conduct energy audits or industrial

assessments and provide recommendations to

manufacturers to help them identify opportunities to improve productivity, reduce waste, and

save energy. This web site contains tools and

publications on energy saving methods and

o p p o r t u n i t i e s .

US EPA Compliance Assistance Centers

<h t t p : / / w w w . a s s i s t a n c e c e n t e r s . n e t>, provide

access to a broad array of information on environmental requirements and everyday issues

faced by specific industry and government sectors. The web site also includes a link to the

Compliance Assistance Platform

<w w w . e n v a p . o r g>, a rich resource for state

environmental compliance assistance tools and

environmental topics. 

US EPA Small Business Advocate and Gateway,

<h t t p : / / w w w . e p a . g o v / s b o>. US EPA’s portal

for finding information that pertains to small

b u s i n e s s e s

Water Efficiency Manual for Commercial, Industrial and Institutional Facilities <h t t p : / / w w w .

p 2 p a y s . o r g / r e f / 0 1 / 0 0 6 9 2 . p d f>. North Carolina’s Division of Pollution Prevention and Environmental Assistance web site which offers

information and links geared toward small businesses, including information on water and

energy efficiency techniques and environmental

management systems. 

Appendix B

10 Elements of an Environmental 

Management System 

The Commission for Environmental Cooperation

has identified the ”10 Elements of Effective

Environmental Management Systems“:

1. Document and clearly communicate an environmental policy. 

2. Clearly communicate all environmental

requirements and voluntary undertakings.

3. Establish specific objectives and targets and

establish appropriate time frames to meet those

objectives and targets. 

4. Establish the structure, responsibility and

resources to ensure that the organization is

equipped with sufficient personnel and other

resources to meet the objectives and targets of

its EMS.

5. Identify and provide for the planning and

management of all the organization’s operations

and activities with a view toward achieving the

objectives and targets.

6. Establish and maintain corrective and preventive action and emergency procedures. 

7. Ensure adequate training and competence of

e m p l o y e e s .

8. Describe how the "10 Elements" will be integrated into the organization’s overall decision

making and planning.

9. Establish and maintain document control.

10. Require continuous evaluation and improvem e n t .

The full text of the "10 elements" can be found

at: <h t t p : / / w w w . c e c . o r g / p u b s_d o c s / d o c um e n t s / i n d e x . c f m ? v a r l a n=e n g l i s h & I D=2 4 3>.
31 A N O R T H A M E R I C A N P E R S P E C T I V E

References 

Bergeson, L. 2004. New EPA policy promotes

EMS. Pollution Engineering. July 1.

<http://www.psi.org.uk/docs/2003/research/

env-reg-relief-PSI-data-analysis-report.pdf>.

CEC (Commission Environmental Cooperation).

2000. Improving environmental performance

and compliance: 10 elements of effective environmental management systems. Montreal:

CEC, June. <h t t p : / / w w w . c e c . o r g / p u b s_d o c s /

d o c u m e n t s / i n d e x . c f m ? v a r l a n=e n g l i s h & I D=2 4 3>

CFIB (Canadian Federation of Independent

Business). 2001. SMEs: The natural facts.

<h t t p : / / w w w . 1 4 0 0 0 r e g i s t r y . c o m / p d f / f a c t s . p d f>

Coglianese, C. and J. Nash. 2002. Policy

options for improving environmental management in the private sector. E n v i r o n m e n t 4 4 ( 9 ) :

1 0 – 2 3 .

Environment Canada. 2003. Environment Canada SME programs: Sharing lessons learned.

Ottawa: Environment Canada, July.

Florida, R. and D. Davison. 2001. Why do firms

adopt advanced environmental practices (and

do they make a difference)?

w w w . h e i n z . c m u . e d u /~f l o r i d a / p a g e s / p u b / w o r k

i n g - p a p e r s / e m s . p d f .

Hillary, R. 1999. Evaluation of study reports on

the barriers, opportunities and drivers for small

and medium sized enterprises in the adoption

of environmental management systems. 

Network for Environmental Management and

Auditing <h t t p : / / w w w . i n e m . o r g / h t d o c s / i s o /

h i l l a r y . h t m l>.

-———. 2004. Environmental management

systems and the smaller enterprise. Journal of

Cleaner Production 12: 561–69.

IADB (Inter-American Development Bank).

2004. Multilateral Investment Fund (MIF),

implementation of quality management systems

under MIF’s ISO cluster: Does it make a differe n c e?

<h t t p : / / w w w . c e c . o r g / p u b s_d o c s / s c o p e / i n d e x

. c f m ? v a r l a n=e n g l i s h & I D=1 5> (under Reports

section). 

IFC (International Finance Corporation). 2004.

Manual for implementing EMS in SME.

<h t t p : / / w w w . i f c . o r g / i f c e x t / e n v i r o . n s f /

Content/ EMS>.

Lexington Group. 2002. Proyecto Administración Ambiental Monterrey,

<h t t p : / / w w w . c e c . o r g / p u b s_d o c s / s c o p e / i n d e x

. c f m ? v a r l a n=e n g l i s h & I D=1 5> (under Reports

s e c t i o n ) .

Matthews, D. H. 2001. Assessment and design

of industrial environmental management syst e m s. PhD dis., Department of Civil and Environmental Engineering, Carnegie Mellon

University, Pittsburgh.

Nash, J. 2000. Voluntary codes of practice:

Non-governmental institutions for promoting

environmental management by firms.

<h t t p s : / / d s p a c e . m i t . e d u / b i t s t r e a m / 1 7 2 1 . 1 /

1602 /1/Nash_p a p e r_F N L . d o c>.

NDEMS (National Database on Environmental

Management Systems). 2003. Final report. February. <h t t p : / / n d e m s . c a s . u n c . e d u />.

NEETF (National Environmental Education and

Training Foundation). 2001. S t a n d a r d i z i n g

excellence, working with smaller businesses to

implement environmental management

s y s t e m s.

<h t t p : / / w w w . g r e e n b i z . c o m / t o o l b o x / r e p o r t s_t

h i r d . c f m ? L i n k A d v I D=2 1 8 0 4 & C F I D=3 9 5 5 3 8 & C

F T O K E N=6 5 6 4 8 9 8 8>

OECD (Organisation for Economic Co-operation and Development). 2002. OECD small

and medium enterprise outlook 2002. Paris:

OECD. <h t t p : / / w w w 1 . o e c d . o r g / p u b l i c a t i o n s /

e - b o o k / 9 2 0 2 0 9 1 E . p d f>.

Pacific Institute for Studies in Development,

Environment, and Security. 2000. Managing a

better environment: Opportunities and obstacles for ISO 14001 in public policy and comm e r c e, J. Morrison, K. Kao Cushing, Z. Day,

and J. Speir, ed. Oakland, CA: Pacific Institute.

Russo, M. V. 2000. Institutional change and

theories of organizational strategy: ISO 14001

and toxic emissions in the electronic industry.

Paper presented at the 60th annual meeting of

the Academy of Management, Toronto.

TCEQ (Texas Commission for Environmental

Quality). 2003. A model environmental management system for a small business: metal finisher, Austin.

<h t t p : / / w w w . t c e q . s t a t e . t x . u s / c o m m_e x e c / f o r m s

_p u b s / p u b s / g i / g i - 3 0 4 a_1 7 2 6 4 1 . p d f> .
32 E N V I R O N M E N T A L M A N A G E M E N T S Y S T E M S

US EPA (US Environmental Protection Agency).

2004a. National Environmental Performance

Track: EMS criteria. <h t t p : / / w w w . e p a . g o v /

performancetrack/program/ems.htm. 2004b>.

Strategy for determining the role of environmental management systems in regulatory prog r a m s.

Welch, Thomas. 1998. Moving beyond environmental compliance. Boca Raton, FL: Lewis

P u b l i s h e r s .

World Bank. 1998. Mexico: The Guadalajara

Environmental Management Pilot.

<h t t p : / / w w w . w o r l d b a n k . o r g / n i p r / w o r k_p a p e r

/ g u a d a />.

World Environment Center, 2005, The WEC

Supply Chain Management Partnership,

<http://www.wec.org/docs/WEC%20Supply%

20Chain%20Management%20Partnership.doc>

Commission for Environmental Cooperation

393, rue St-Jacques Ouest, Bureau 200

Montréal (Québec) Canada H2Y 1N9

i n f o @ c e c . o rg

h t t p : / / w w w. c e c . o rg