Abstract: . . .  shift environmental responsibility from environmental staff to line functions in a number of ways ranging from the requirement to specify roles, responsibility and authorities to mandating training, awareness and competence for all employees. Its most effective provision, however, is the requirement to implement various components of the EMS “at each relevant function and level of the organization.” This clause appears repeatedly throughout ISO 14001 and was specifically inserted to effect a transformation in environmental responsibility from staff to line functions. Over time, the cumulative effect of increasing line responsibility is to change employee awareness and behavior and ultimately to change the internal culture of the organization. . . .
. . .  evaluation of the EMS leaves out all mention of top management. It simply requires a program for such evaluations that include “the results of assessments, revisions to the manual, and communicating findings and action plans to affected employees, onsite service providers, and contractors.” Top management is nowhere to be seen in the review of the EMS under CF/EMS. Chart 2. Comparison of ISO 14001 , CEMP and CF/EMS Against Relevant Systems Criteria Operational Clarity Consistency Breadth Line Responsibility Culture Change Compliance Management Involvement ISO 14001 10 10 10 9 8 8 10 CEMP 3 2 6 7 4 10 5 CF/EMS 9 2 8 5 4 10 5 Range: 1 to 10 (10 = highest satisfaction of criterion)  . . .
. . .  communicating findings and action plans to affected employees, onsite service providers, and contractors.” Top management is nowhere to be seen in the review of the EMS under CF/EMS. Chart 2. Comparison of ISO 14001 , CEMP and CF/EMS Against Relevant Systems Criteria Operational Clarity Consistency Breadth Line Responsibility Culture Change Compliance Management Involvement ISO 14001 10 10 10 9 8 8 10 CEMP 3 2 6 7 4 10 5 CF/EMS 9 2 8 5 4 10 5 Range: 1 to 10 (10 = highest satisfaction of criterion)  . . .
. . .  communicating findings and action plans to affected employees, onsite service providers, and contractors.” Top management is nowhere to be seen in the review of the EMS under CF/EMS. Chart 2. Comparison of ISO 14001 , CEMP and CF/EMS Against Relevant Systems Criteria Operational Clarity Consistency Breadth Line Responsibility Culture Change Compliance Management Involvement ISO 14001 10 10 10 9 8 8 10 CEMP 3 2 6 7 4 10 5 CF/EMS 9 2 8 5 4 10 5 Range: 1 to 10 (10 = highest satisfaction of criterion)  . . .
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