Knowing your EMAS from your ISO

The business of certification is a tall tree with tangled branches. For the company looking to scale the heights of an international standard – say ISO 14001, which specifies the requirements of an Environmental Management System (EMS) – it can be difficult to know whom to ask for a legup; but asking the wrong people can mean missing out on some important clients.

ISO itself states openly in the FAQ section of its website that “ISO standards are voluntary” and that “ISO has no power to enforce the implementation of the standards it develops”. Neither is certification mandatory as evidence of compliance, which may surprise some companies that have invested time, money and effort in the consultancy and conformity assessment process that leads up to that achievement.

There is no barrier, then, to a company simply proclaiming, and indeed publicising, its conformity to an ISO standard through self-assessment. So why certify at all? As ISO notes, many companies choose certification as an independent verification of their compliance. But here, too, it may come as a mild shock that there is no legal impediment to starting a company populated by self-appointed auditors and setting about the business of handing out certificates.

The next branch up the tree, which attempts to lend credibility to the entire practice, is accreditation – in the technical sense of the word, the matter of assessing the competence of certification bodies. In the UK, the only body recognised by Government to perform this task is UKAS, the United Kingdom Accreditation Service.

Again, however, there is nothing to stop anybody from issuing accreditations. There are international standards for the performance of both accreditation and certification bodies – respectively ISO 17011 and ISO 17021, the latter of which is currently coming into effect – but both, again, are voluntary.

According to UKAS head of marketing and communications Jon Murthy, the benefits of choosing a UKAS-accredited certifier are tangible: “An essential element of the UKAS assessment process is witnessing the assessment of a supplier by the certification body. This will reveal whether the assessment process is sufficiently rigorous and robust in determining the supplier’s compliance with the certification standard.”

Graham Walford, EMS product manager at UKAS-accredited certification body SGS UK, concurs, saying: “Accreditation deals with impartiality, competence of auditors and independence. We are subject to regular auditing and surveillance by UKAS – they come to our offices to interview management and staff, review client files and also witness our auditors performing audits at clients’ sites.

“Customers know they’re getting a certification body with recognised accreditation that isn’t just recognised in this country, but known globally. They can be confident that we have well qualified, well trained auditors familiar with the standard and the environmental issues and legislation of the industrial sector concerned.”

But despite a bilateral Memorandum of Understanding (MoU) between UKAS and the Department of Innovation, Universities and Skills (DIUS) naming UKAS as the UK’s sole recognised accreditation body, the recognition ultimately establishes no legal rights or liabilities.

Nonetheless, Murthy says that the MoU “underpins UKAS’s unique position within the UK and demonstrates the international recognition that UKAS enjoys”.

This is also demonstrated by the UKAS logo, which incorporates the Royal Crown under licence from DIUS. An accredited certification body has the right to use the mark on its certificates, and a company can use it to publicise certified services, as seen on a number of ad pages in this publication each month.

Given that master copies of the UKAS marks, as well as instructions for their proper reproduction, are in the public domain on the UKAS website, they would not be difficult to forge. There is, however, a three-figure accreditation number unique to each certification body which must be used alongside the mark under the terms of the licence, and improper use is subject to the Trade Descriptions Act 1968.

The proprietary rights associated with the mark must be jealously guarded. “We undertake regular assessments of our accredited organisations,” says Murthy, “which include detailed reviews of how they are managing the use of logos (particularly UKAS ones) by their certificated clients.” However nonaccredited certification bodies and their clients are not covered by this scrutiny, so it requires a knowledgeable and vigilant buyer to identify where a UKAS logo is used improperly.

No figures are available for the number of EMS certificates handed out by non-UKAS-accredited certification bodies each year, because they necessarily operate outside the recognised system. But neither is there an authoritative database of ISO 14001 certificates awarded by accredited bodies, although ISO, The Stationery Office, and PMM itself all assemble lists periodically (see PMM Special Report, August 2007).

All depend upon voluntary disclosure by accredited certification bodies, which may decline to list the companies they have certified since they consider the information commercially sensitive, worrying that it simply provides a directory of customers for their competitors to poach.

The only foolproof way of verifying an EMS certificate is to contact the certification body whose accreditation number accompanies the UKAS mark (all of these numbers are on the UKAS website), and to reference the number of the certificate and the name of the supplier claiming it. A few certification bodies also provide search tools on their own websites that allow users to check the provenance of certificates they have issued by entering the name of the supplier and/or the certificate number.

While EMS certification is already receiving a great deal of attention within the graphic arts industry, there is perhaps less general awareness of the rights and responsibilities that UKAS-accredited certification specifically entails.

According to Walford, “potentially there are a significant number of companies, particularly SMEs, that don’t know the difference between accredited and unaccredited certification”.

Since 2000, UKAS has been given Government funding “to promote accreditation and to ensure that the profile and value of accredited services is fully understood”, says Murthy. This came as a result of a review “initiated in response to complaints, particularly from SMEs, about non-accredited certificates not always being accepted by purchasers.

“Since then, the campaign has actively promoted the benefits of accredited certification to Government, local authorities and to the business community. As a result, the number of complaints from SMEs relating to non-acceptance of certificates has significantly reduced.”

He adds: “UKAS has recently submitted a bid to DIUS for continued funding to carry out a three-year programme of awareness activity.”

A fact of which many seem to remain unaware is that, unlike the ISO standard, it is a legal requirement of bodies issuing the EU’s Eco-Management and Audit Scheme (EMAS) certificates that they be accredited by a member of the European co-operation for Accreditation (EA). UKAS is the UK’s only current member, and under the draft EU regulation COM(2007) 37, will eventually become the only body eligible for membership.

But despite these built-in protections, take-up of the EMAS scheme in UK print has been very sluggish, judging by PMM research in August 2007. The PMM Special Report found only seven printers at that time certified to EMAS, compared with around 200 that had ISO 14001 certificates. An estimated 300 printers now have ISO 14001, with a further 300 believed to be working towards it.

Polestar’s gravure printing site in Sheffield was awarded its ISO 14001 certificate by ISOQAR just over a year ago, and the site’s health, safety and environmental manager at the time, John Holland, suggests reasons for the comparatively slow take-up of EMAS may be that it is “not as user-friendly and not as flexible”.

The scheme is an extension of ISO 14001, and an EMS that meets the standard is a criterion of EMAS compliance. However, says Walford, “with EMAS, you must also produce a publicly available environmental statement that reports performance against legal requirements and key environmental issues such as energy consumption and waste management.”

He gives two reasons for the low demand for EMAS: “Firstly, a lot of companies can’t see the additional benefit in the public reporting; and secondly, ISO 14001 is an international standard, while EMAS is a European standard.”

In any case, ISO 14001 appears to satisfy the supply chain’s conscience at present. Furthermore, the value of the standard proves itself through financial as well as environmental benefits, not to mention industry recognition like Polestar Sheffield’s PPA award for Environmental Performance of the Year.

Holland notes: “If you’re very good at environmental management you can’t help but save money, whether you’re saving it because you’re efficient energywise, or you’re saving it because you’re efficient process-wise.

“For example, if there is a splice break on a gravure press, at the very minimum it’s going to cost 600 metres of paper because that’s the length of the press. In reality, by the time you’ve run back up to speed and good copy, you’re talking perhaps two or three thousand metres. From a financial point of view, that’s a waste of money; from an environmental point of view, it’s a waste of resources.

“It’s a matter of offsetting – if a web break is costing us 600 metres of paper because the temperature’s low, what’s it going to cost to increase the heat to solve the problem? As long as the cure isn’t as distasteful as the problem, then it’s okay to do it.” This is the kind of decision making process – along with the mantra of reduce, reuse, recycle – that an EMS actually covers.

But even though the requirements are fairly intuitive (all ISO standards are intended to be performance- and not design-based), they take time, money and effort to implement. Holland explains that there are several steps to success, including gap analysis costing perhaps £8,000 for a large site, consultation at £7-800 a day and then the £3-4,000 assessment.

On top of this, the EMS must be implemented for three months before it can be assessed and must be audited biannually. Three major non-conformities will send the auditors packing and require a whole new assessment.

Care must be taken, too, when investing in the advice of consultants. Firstly, the terms of the ISO standard for conformity assessment specify that any certification body also providing consultancy services must keep the two activities separate in order to avoid potential conflicts of commercial interest – such as if your driving test were carried out by your instructor.

Secondly, says Holland: “It’s only within your own business that you can understand what’s achievable, what isn’t achievable, and what your customers want. You can’t go outside for that.” Holland is particularly well placed to know this as a qualified lead auditor of management systems himself, which was an advantage to his company during the assessment process: “When we built our management system, I knew that everything hanging off that met the standard. So when the auditors come in as they do every six months and pull the place apart, without losing too much sleep I know that at the very least the systems meet the requirements.”

It means he also understands what is required of the auditors sent by ISOQAR to assess the site’s EMS. As if the situation weren’t already complex enough, auditors themselves need to be assessed as competent, which is yet another branch to the certifications tree. There is a guideline standard for what is expected of an EMS auditor – ISO 19011 – but once again, there is no UK or EU law governing certification to this standard.

Any person may identify him- or herself as an auditor competent to certify a management system to ISO 14001. However, the most widely recognised body for certifying auditors is the International Register of Certificated Auditors. IRCA is almost unique in that it issues certificates widely accepted as credible while working above the accreditation system although IRCA does have one UKAS-accredited certification scheme).

According to IRCA director, Simon Feary: “We are established at the top of the tree because people are happy with our brand and what we as an organisation represent.” However, IRCA only certifies what Feary calls “generic competence”. The quality of an auditor’s output depends upon thorough sectorspecific training being given by the assessment body employing him or her.

“One assumes that sound, credible certification bodies do indeed do that,” Feary continues. “However, there is a great debate at the moment in the auditing industry that the credibility of third party certification is being compromised by incompetent audit.” As he puts it: “Competence depends on context.”

Although there is no sure-fire method of guaranteeing the standard of training that an auditor receives from a certification body in any given industry sector, Feary says that in the UK, a UKAS-accredited body is certainly the best bet:

“I wholeheartedly support UKAS-accredited certification, because unaccredited certification serves no useful purpose. You can have accredited certification, which can give people confidence because of the UKAS logo; or you can have unaccredited certification, which gives no confidence unless you’re already confident in the brand.”

But although the draft EU regulation will eventually tighten the structures of accreditation across Europe, reducing different interpretations of standards across the Community, it will still not have the power to make certification a requirement of meeting an ISO standard, nor to make accreditation a requirement for handing out certificates.


• www.ukas.com
• www.irca.org
• www.iso.org
• www.sgs.com