ISO 14001 versus LWG audit protocol – Key differences
ISO 14001 and the LWG audit do not assess environmental performance in the same terms.
The LWG audit quantifies environmental performance whereas the ISO standard does not.
The LWG protocol is an industry specific standard that makes direct reference to quantifiable
procedures; it measures and records the degree to which environmental performance is
demonstrated. The importance of an Environmental Management System is recognised and
is a component part of the LWG protocol. The operation of ISO 14000 or other recognised
standard is recognised over and above internally derived Environmental Management
Systems but is not considered an alternative to the LWG protocol for several reasons:
1. The LWG protocol is designed to ensure that the entire supply chain of leather
manufacture can be shown to have attained a measurable level of environmental
performance. Although some tanners process from raw hide to finished leather many
process only some of the stages, i.e. wet blue to finished leather or crust to finished
leather. The assessment and scoring of LWG is designed to encourage and reward
upstream environmental performance. ISO 14000 relates only to the organisation
being assessed, an organisation that could conceivably be obtaining inputs from
polluting suppliers. The higher grades in the LWG rating mechanism can only be
attained if the entire supply chain starting from raw hides has attained a common and
measurable level of performance.
2. The ISO standard relates to the management system and is explicit in not attempting
to quantify environmental performance, indeed, in the introduction it states
“This International standard does not establish absolute requirements for
environmental performance beyond the commitments, in the environmental
policy, to comply with applicable legal requirements and with other requirements
to which the organisation subscribes, to prevention of pollution and to continual
improvement. Thus, two organisations carrying out similar operations but having
different environmental performance can both conform to its requirements” (our
italics).
In contrast the LWG rating system is expressly designed to measure and rate
environmental performance. The LWG audit proclaims
“The purpose of this [LWG] tannery auditing protocol is to evaluate the
environmental performance of tannery operations”
The LWG protocol assesses tannery operations in absolute terms, for example
energy requirement to produce a square foot of leather, proportion of wastes
recycled etc.
3. The introduction to ISO further states
“…adoption of this standard will not in itself guarantee optimal environmental
outcomes”.
The scoring and rating system within the LWG protocol, using questions aligned to
industry specific technologies, is designed to enable tanneries to measure
environmental performance, benchmark themselves against their peers, identify
strengths and weaknesses in environmental performance and thereby enable them
to identify the actions required to attain optimal environmental outcomes.
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4. The ISO standard makes no demands on an organisation to achieve a recognised
level of performance
1 Scope “… It does not itself state specific environmental performance criteria….
As indicated above, the LWG protocol is based on tanneries attaining specific
performance criteria to gain a rating.
5. The ISO standard indicates that results can be measured against the company’s own
standards
3 Terms and definitions…“…NOTE In the context of environmental management
systems (3.8), results can be measured against the organization's (3.16)
environmental policy (3.11), environmental objectives (3.9), environmental targets
(3.12) and other environmental performance requirements…”
This would not lead to transparency for customers unless those standards are
expressly quantified and stated. In contrast LWG results are measured against
common performance guidelines, not against the variable measures that occur when
organisations define their own objectives or requirements.
6. Both audit protocols make reference to legal compliance although the ISO standard
is worded less strongly, referring to commitment to comply rather than a requirement
to comply;
Section 4.2 Environmental policy subsection (c) “… includes a commitment to
comply with applicable legal requirements and with other requirements to which
the organization subscribes which relate to its environmental aspects…”
LWG goes beyond a commitment to comply with applicable legal requirements and
insists on actual compliance with the requirements of operating permits and other
legal requirements. Several ISO certified companies have failed the LWG audit for
failing to comply with legal requirements. During the course of some of these LWG
audits, when questioned as to how the company managed to attain ISO certification
despite failing to act in accordance with permit/legislative requirements or by
discharging untreated affluent it was confirmation was given of ISO certification
having been awarded due to the company’s commitment to future compliance.
7. The phasing “…and with other requirements to which the organization subscribes…”
limits the compliance requirements of the company. For example, a major impact on
the global environment is threatened by the continual destruction of the Amazonian
biome. This threat has been identified by many organisations and initiatives have
been developed to halt deforestation and the associated human rights abuses in the
areas where it is occurring. Unless specifically requested by the customer there is
limited requirement outside of LWG to declare the extent of traceability of raw
material and therefore the potential impact of this aspect of a company’s operations
could be, and frequently is, overlooked. It is a requirement of the LWG protocol that
the degree and method of traceability of raw material is demonstrated. The grading
system allows comparison of the extent and robustness of traceability within the
supply chain.
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8. Legal requirements vary considerably from country to country and often from state to
state within countries. Legal compliance imparts no information about environmental
performance other than with respect to the country in which the organisation is
operating.
4.3.2 Legal and other requirements
The organization shall establish, implement and maintain a procedure(s)
a. To identify and have access to the applicable legal requirements and other
requirements to which the organization subscribes related to its
environmental aspects, and
b. To determine how these requirements apply to its environmental aspects.
A.3.2 Legal and other requirements
The organization needs to identify the legal requirements that are applicable to its
environmental aspects.
Examples of other requirements to which the organization may subscribe include,
if applicable …agreements with customers…
It cannot be argued that ISO 14000 is an alternative to the LWG protocol. On the
contrary, as the ISO standard indicates
4.3.2 Legal and other requirements
The organization shall establish, implement and maintain a procedure(s)
to identify and have access to the applicable legal requirements and other
requirements to which the organization subscribes related to its
environmental aspects, and
to determine how these requirements apply to its environmental aspects.
The organization shall ensure that these applicable legal requirements and
other requirements to which the organization subscribes are taken into
account in establishing, implementing and maintaining its environmental
management system.
This requirement of ISO 14000 indicates that if the customer requires the supplier to
undergo an LWG audit so as to quantify environmental performance it is a condition
of ISO certification that the supplier takes this requirement into account.
9. The ISO certification requires the setting of targets; however these can be set
internally by the tannery and do not necessarily have any relationship with targets
attainable generally within the industry.
4.3.3 Objectives, targets and programme(s)…“The organization shall establish,
implement and maintain documented environmental objectives and targets, at
relevant functions and levels within the organization. The objectives and targets
shall be measurable, where practicable, and consistent with the environmental
policy, including the commitments to prevention of pollution, to compliance with
applicable legal requirements and with other requirements to which the
organization subscribes, and to continual improvement.”
LWG goes beyond targets and defines specific environmental performance. Without
expressly comparing and reporting performance data against companies undertaking
a similar range of operations the attainment of ISO certification provides little
information to stakeholders. For example, a tanner using 100MJ per square ft. of
leather produced could have a stated aim to achieve a 10% reduction, and may do
so, fulfilling the requirements of ISO certification! However this imparts no useful
information to stakeholders. ISO certification in this case could even be considered
misleading if the majority of tanners undertaking the same range of operations were
already operating at an average of 50 MJ per square foot of leather produced. LWG
provides transparency and awards achievement (i.e. low energy usage) as opposed
to intention (i.e. to reduce energy usage).
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10. The rating of the companies audited is dependent upon a defined level of
performance across all environmental aspects. Tanners who have attained ISO
14000 generally score better in the LWG audit than tanners who have not (41% of
audited tanners with ISO 14000 scored Gold in LWG compared to an overall average
of 21.5% of tanners attaining Gold). However failure of the LWG audit can also occur,
but only on two counts –
a. failure to comply with permit conditions or legislation
b. Discharge of untreated effluent to water courses
Of the 10 companies that have failed the LWG audit, 7 had ISO 14000
certification. Although this may be the fault of individual auditors rather than ISO
1400 per se, this is perhaps the most damning illustration that ISO 14000 is not
completely fulfilling the requirements of the brands.
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