There is rising concern that current approaches to environmental management systems are yielding little in the way of meaningful environmental performance improvement. No small concern because the scale of the investment in EMS is colossal, but often underestimated. Over 95% of the real economic cost of EMS is attributable to factors which are difficult to measure - time inputs from personnel working within organizations on program development (drafting and reviewing policies, procedures and the like), training (most personnel will be trained), auditing (internal and maybe 3rd party) and very especially the pre-audit blitz that precedes most audits by 3rd parties.

Concerns about the value derived from implementing and certifying EMSs have not impacted growth in the field. Indeed there has been a significant uplift in the level of activity with the European Commission, EU Member State governments, US State and Federal government agencies joining with industry sector associations and others in the call to promote – and in many cases require - the uptake of management systems and third party certification of them.

US regulators in the state of Texas and other US states are offering meaningful incentives to organisations who meet a defined set of EMS requirements

The American Chemistry Council is requiring all of their members to implement certified EMSs by the end of 2006.

The US EPA has included requirements for 3rd party approved EMS’s in sentencing guidelines.

Those who are voicing concerns about the value of EMS point to an increasing body of anecdotal and empirical evidence which has found little or no correlation between certified EMSs and a variety of environmental performance metrics. The findings of these studies are surprising for many: the broad-based uptake of management systems in the environmental field was seen as a natural progression away from end-of-pipe thinking and most expected it to lead to significant operational efficiencies and other environmental performance gains.

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