ISO/TC 207 N418
June 17, 2000

Discussion Paper
ISO/TC 207 NGO Contact Group


NGO members of TC 207 national delegations along with members of NGO observer delegations first met with the ISO/TC 207 leadership in San Francisco in June 1998. This was an important event, allowing NGOs to express their interest in the ISO 14000 standards, the ISO standards development process, and effective NGO participation in ISO/TC 207. Following this meeting, ISO/TC 207 passed Resolution 21/1998 to form an NGO Contact Group (See Annex 1) and to investigate NGOs' concerns expressed during the San Francisco meeting.

In 1998-1999 the NGO Contact Group conducted a survey of national standards setting bodies and carried out interviews with several NGOs to determine the extent of and the barriers to effective NGO participation in the ISO/TC 207 process. Most national bodies that responded to the survey disclosed that some mechanisms were in place to involve NGOs in the standards setting process. Many countries also reported the presence of NGOs in their national bodies and in the national delegations to the ISO/TC 207.

The findings of the survey were reported at the June 1999 ISO/TC 207 plenary in Seoul and were discussed at a meeting of the ISO/TC 207 leadership with NGO representatives. This meeting concluded that although NGOs participate in limited numbers, there has been a valuable input from NGOs to the development of the ISO 14000 series of standards. At the same time, the findings of the survey were open to different interpretations due to potential ambiguity in its definition of 'NGOs' and its sample of respondents. In particular, some NGOs believed that the results of the survey confirmed that the actual NGO participation in the TC 207 process is low relative to the participation of industrial representatives, standards bodies, governmental representatives and consultants.

Interviews with individual NGOs from the US, Japan, Australia, Singapore and the Netherlands demonstrated their awareness of both the ISO/TC 207 process and its potential public policy implications. However, some NGOs did not participate in the process (except for monitoring its outcomes) because they perceived that the costs of such participation would outweigh the benefits. These NGOs felt that by allocating their scarce human, financial and other resources to other areas they can achieve better results. Participation in the ISO 14000 process was, thus, considered as less efficient than participation in direct public policy-setting processes.

For purposes of this paper, an NGO is a non-profit association of citizens that operates independently of government or business structures and has non-commercial objectives related to environmental, consumer interest or sustainable development.

One interviewed NGO had decided to put its limited resources in promoting a sound implementation of the ISO 14001 EMS standard at the national level by participating in a panel of experts that provides binding interpretative guidance on ISO 14001 to certification bodies. The interviewed NGO considered this to be an effective contribution to the inter-linked standardization-implementation-certification system.

At the ISO/TC207 closing plenary in Seoul, Resolution 20/1999 was passed by ISO/TC 207 instructing the NGO Contact Group to seek to achieve further understanding of NGO issues and seek to enhance NGO participation by undertaking actions including the preparation of this discussion paper. This paper was prepared jointly by the NGO Contact Group and representatives of NGOs who were present at the 8th TC 207 Plenary Meeting in Stockholm (see Annex 1). In accordance with the ISO/TC 207 Resolution 20/1999 it examines:

  • The value of NGO input into the ISO/TC 207 standards setting process
  • Motivation for NGO participation in the ISO/TC 207 standards setting process, including those associated with public interest groups
  • Procedures for improving NGO capacity to interact with ISO/TC 207
  • Examples where ISO/TC 207 standards are used in non-business applications
The definition of an NGO used for the purposes of this paper (see Box) may not fully and accurately reflect the range of groups that will become interested in the ISO/TC 207 process in the future. However, it aims to underline the common features of the non-governmental environmental and consumer organisations that have been so far the most involved in standard-setting and whose activities stimulated the production of this paper.

NGOs' involvement into the TC 207 standards setting process has the following potential values:

  • It supports TC 207's mission "to contribute to sustainable development" which aims "to equitably meet developmental and environmental needs of present and future generations" (Rio Declaration, Principle 3). NGOs' participation can contribute toward development which is more equitable both within the present generation (since NGOs represent diverse social groups whose interests may not otherwise be adequately considered) and in relation to the future generations (since many NGOs seek to represent long-term societal goals which may not otherwise be adequately considered).
  • It ensures that ISO is an impartial and balanced framework for developing standards based on consensus.
  • It is in line with "ISO Long-Range Strategies 1999-2001" which call for 'balanced representation', including 'more effective representation of consumers and of other social forces', express concern about 'transparency of [ISO] activities', and express a commitment 'to ensure the involvement of consumers and of all the other relevant social forces in the various stages of the standards development process'.
  • It could add to the credibility of the ISO 14000 standards (and enhance their competitiveness) through securing the support of NGOs and their constituencies.
  • It could improve ISO 14000 standards by making them sensitive to a wider variety of perspectives and experiences and introducing a balanced approach to key environmental issues.
  • It could enhance the chances of successful implementation of ISO 14 000 standards by encouraging NGOs to increase public awareness, strengthen national and local capacities and monitor practical application of the standards.
In practice, NGO participation in the work of ISO/TC 207 has yielded many positive benefits. For instance, a number of environmental and consumer NGOs participated in developing the ISO 14021 standard. Some were part of national delegations, while others were from international liaison organizations. As a result of their participation, a number of key elements were included in the standards on environmental labels and declarations in the ISO 14020 series specifically at the suggestion of NGOs. For example, every standard in the 14020 series includes a statement detailing the objective of environmental labels and declarations as follows:

The overall goal of environmental labels and declarations is, through communication of verifiable and accurate information that is not misleading on environmental aspects of products and services, to encourage the demand for and supply of those products and services that cause less stress on the environment, thereby stimulating the potential for market-driven continuous environmental improvement.

Without the NGO input, this, and other similar important clauses in ISO 14021 would most likely not have been identified and included. Incorporating these NGO inputs required considerable innovation in the way decisions were taken in working group meetings to ensure that each interest group had an appropriate say in the wording of the 14020 series standards.

ISO 14001 itself benefited from the input of NGO and governmental groups, which resulted in the inclusion of prevention of pollution as an explicit part of the necessary continual improvement commitment. NGO participation was also influential in the development of ISO 14031 on Environmental performance evaluation, especially its main text section on external communications and its Annex section on the identifying the views of interested parties in the context of EPE. Similarly, NGOs' critical review of ISO/TR 14 061 on the application of ISO 14001 in the forestry sector forced the working group to very carefully word the text of TR 14061 on, for example, what a forestry organization can and cannot claim on basis of an ISO 14001 certificate and what sort of information system audits provide.

In practice NGOs also contribute to strengthening national capacities for the implementation of ISO 14000 standards, especially in developing and transitional economies. For example, NGOs increase public awareness of ISO 14000 series of standards, as in Belarus where an NGO issued the first national publication on EMS and ISO 14000. Another example is the Russian Federation, where an NGO runs the key national Internet site on EMS and ISO 14000, co-operates on a number of pilot EMS projects with industries and local governments, and conducts dozens of EMS workshops in many regions of the country.

In summary, NGOs involvement in the ISO/TC 207 process has a number of potential benefits and is in line with the ISO/TC 207 mission and the strategic directions of ISO development. Many, but not all of these benefits have been observed in practice in spite of the fact that NGOs' participation was not as extensive as it could have been.

For much of its 50-year history, ISO was concerned with purely technical standards, the content of which generated little interest outside of the industry bodies that used the standards. Even when International Standards facilitated major industry reform, such as in the containerization of transport in the 1950's and 60's, the process of their development did not significantly interest the broader community. In the 1970's, ISO first became involved in the safety of consumers which was probably the first time that the content of International Standards became of vital interest to the community at large. Since then, ISO activities have gradually expanded to encompass a range of subjects of interest to the general public, such as public information signs, customer complaint handling and, finally, environmental management.

The Standards in the ISO 14000 series deal with the tools that industry uses to help manage its environmental responsibilities. Of all ISO standards, these may have the strongest potential to affect public policy because environmental aspects of organizations' activities addressed by the ISO 14000 series standards are directly linked to environmental issues which have been traditionally dealt with by public policies. The link between the ISO 14000 series standards and environmental policy has been recognized and institutionalized in a number of regulatory systems as illustrated in the next section.

The public policy implications of the ISO 14000 Standards stimulate the interest in these Standards of diverse national and international NGOs. Consequently, NGOs become motivated to influence the standards setting process. The specific motivations for an NGO to participate in the TC 207 process vary depending upon its type, scale of operation and national origin. NGOs believe that the Standards potentially can:

  • Promote improvement in environmental performance of enterprises. For example, environmental NGOs from transitional and developing economies believe that the Standards can encourage industries to go beyond media- and sector-specific environmental standards and can supplement largely ineffective governmental regulation.
  • Enhance corporate transparency and accountability. Consumer groups believe that this could improve the flow of information to the consumers. NGOs from emerging democracies expect that this will support a social dialogue and a rule of law.
  • Reconcile economic and environmental goals. NGOs from low- and middle-income countries concerned with sustainable development believe that a successful introduction of EMS standards can open access to new markets, attract investment, promote economic efficiency and improve corporate governance without jeopardizing the environment.
At the same time NGOs are concerned about possible negative implications of the widespread introduction of the ISO 14000 Standards. NGOs from transitional and developing economies are particularly reluctant to see the Standards introduced in their countries without the necessary attention to their political and institutional contexts and without adequate capacity-strengthening measures. In particular:
  • There is a fear that the Standards may be used to replace rather than supplement existing environmental regulations. Environmental NGOs believe that this may result in worsening environmental performance. While NGOs readily acknowledge that the environmental improvements still eluding us cannot be driven solely by regulation, their concerns about losing the gains of the current regulatory system can overshadow the potential for greater gains. Since ISO 14001 certification mandates neither compliance auditing nor public accountability, NGOs feared that some facilities could ignore regulations under cover of the ISO certification.
  • In low- and middle-income countries where the vast majority of producers lack the capacity to meet the Standards, implementing the Standards could allow few industries capable of gaining certification to monopolize those markets where the certification is a factor.
  • NGOs from emerging democracies are concerned about the situations when certification processes are dominated by traditionally closed bureaucracies and the Standards are implemented in the context of 'administered' non-transparent relations between the industries and the governments.
Thus, NGOs are seeking to influence the ISO/TC 207 process in order to enhance what they perceive as the positive and to reduce the negative potential of the ISO 14 000 series standards. Despite these strong motivations for participation, a number of factors have discouraged a greater NGO involvement. Some of these factors were identified during interviews conducted by the NGO Contact Group as discussed in the Background section. The key factor has been the perceived low efficiency of NGO participation. This, in turn may be linked to their relatively small resources as compared to the resources of other participants. (See, for example, the letter from WWF to ISO/TC 207 (Annex 2) demonstrating that even larger international NGOs find it valuable but difficult to afford to participate.) The ISO/TC 207 process is clearly most heavily influenced by the private sector, which discourages greater NGO participation. Recommendations summarized in the last section of the paper deal with this issue.

The ISO 14000 standards, particularly the ISO 14001 EMS standard, are emerging as useful elements of public policy in many countries around the world. While the concept of an environmental management system was originally conceived as a tool for business, primarily manufacturing, all of the standards have been consciously written so that each would have as wide a potential as possible for use outside of manufacturing organizations. The majority of organizations that have now become certified to ISO 14001 are, as expected, from the manufacturing sector. Nonetheless, there is a rising use of several of the standards outside of manufacturing and outside of the private sector, particularly by government agencies.

Real-life examples of the use of Environmental performance evaluation (EPE) and ISO 14031 as an environmental management tool by some service providers, a local government and an NGO may be found in ISO TR 14032, in addition to a series of real examples from manufacturing companies.

Government agencies are using ISO 14001 in much the same way as their business counterparts, i.e. as a tool to assist in the management of their environmental aspects. More than 100 prefectures in Japan are either already certified to ISO 14001 or somewhere in the process of doing so. Similar organizations around the world, for example, The US Postal Service and the New York City Transit Authority are also reportedly implementing ISO 14001.

Other governmental agencies are using some of the ISO standards in very different and innovative ways, i.e. in ways to support their responsibilities for oversight of public activities. For example, ISO 14021 is moving towards being the legally recognized benchmark for environmental marketing claims in Europe, Canada and Australia and the WTO has adopted the ISO classification system for environmental labelling that was developed in TC 207.

Some government authorities are using ISO 14001 in conjunction with regulatory instruments with the expectation that widespread implementation of EMSs will itself improve environmental quality while allowing them to focus their attention more effectively. The approach taken varies from country to country but most are based on the acknowledgment that ISO 14001 provides a sound basis for a company's control over and improvement of its environmental aspects, including providing for legal compliance. Governmental authorities can then focus on the policy and objectives of an organization and on the ultimate environmental performance achieved as shown in the example given below.

In the Netherlands, implementation of ISO 14001 provides the opportunity for a facility to obtain an "environmental license on main issues" which specifies environmental performance levels rather than the technical means to achieve these objectives. The ISO 14001 system (preferably certified) provides the confidence that the company can manage its environmental aspects in a sound way and that it will be able to achieve the specified environmental performance levels. All applicable environmental regulations are enforced on the basis of reports on environmental performance provided by the companies; those reports may be externally verified to ensure their reliability and accuracy.

Several Dutch environmental NGOs supported this approach as long as it is independently demonstrated that the EMS is functioning well, the company report on environmental performance are available to the general public; the company maintains a sound compliance track record; the environmental license should contain clear and enforceable requirements; and interested parties are able to influence the organization's policy and environmental programme as far as these are part of the license.

The European Union has recognized the potential of ISO 14001 by making reference to this standard in the draft revision of EMAS (the European Eco-Management and Audit Scheme) instead of formulating their own environmental management system requirements as was done in the first edition of EMAS.

EA guidance for the UK oil and gas sector requires that an Environmental Management Plan incorporating an EMS certified to ISO 14001 is included in an Environmental Statement approved by authorities prior to activity's implementation. A similar approach was recommended for developing and transitional countries.

Regulatory authorities in the United States on both the national and local levels are recognizing the potential of ISO 14001. For example, implementation of an ISO 14001 system is one of the entry criteria for a proposed regulatory relief approach by the national Environmental Protection Agency. Other entry criteria include:

  • environmental performance measurement and reporting;
  • compliance assurance and auditing programs;
  • an emphasis on pollution prevention; and
  • stakeholder involvement in the design and implementation of EMSs.
In summary, though ISO EMS standards are not a regulatory instrument, they are increasingly integrated by governments into existing environmental regulatory approaches. This is another demonstration of the value of these standards in public policy arena and justifies NGOs' interest in them.

Full and equitable stakeholder involvement in the ISO 14000 standard setting process will provide the following societal benefits:

  • Greater public credibility of the standards;
  • Standards that result in demonstrable improvements in environmental performance;
  • Increased economic value and reduced environmental liability to companies having ISO 14001 certification;
  • More efficient use of government resources as attention shifts to regulation of non-performers.
ISO TC207 leadership has a responsibility to ensure that NGOs continually participate in the ongoing standards process as representatives of public interests and that their of participation is enhanced both in depth and in breadth. This is particularly critical as the revision of ISO 14000 series proceeds since their input will ensure that the issues of accountability and transparency will be debated and will evolve within the TC 207 process. The entire ISO 14000 series should be viewed as living documents, documents that will evolve and change as participants representing all stakeholder groups reach a higher comfort level with implementation.

The scale and the value of NGO participation in the TC207 process can be significantly enhanced by taking the following steps:

  • broadly communicating the findings of this Discussion Paper within ISO/TC 207, member bodies and to external parties;
  • identifying the best national practices for involving NGOs in standard setting processes in both developing and developed countries;
  • identifying best practices of international bodies (such as the UN) for consulting NGOs and enabling them to participate in their activities and processes;
  • investigating the possibility of modifying TC 207 process in line with these best practices, innovations within the TC 207 subcommittees (see, e.g., p. 3 on the work on the 14020s series standard) and possibly with ICSCA recommendations (Annex 3);
  • improving two-way communication between TC 207 and NGOs world-wide;
  • encouraging NGO networking, educational and other initiatives aimed at increasing their knowledge of and participation in the TC 207 process;
  • identifying and developing funding mechanisms to facilitate NGO participation.
These issues could be best resolved within a special TC 207 Task Group. Such a body should provide for membership of NGOs of different types and geographic areas. The Task Group should also develop a mechanism for engaging and representing the broader international NGO community.
Annex 1. Members of the NGO Contact Group and NGO representatives who participated in drafting of this paper
Annex 2. Letter from WWF to TC 207
Annex 3. ICSCA Recommendations