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Attachment B - EMS Steering Committee Internal Discussion Paper
EMS Steering Committee
Advice on appropriate roles for industry and the nature of partnerships to allow industry, community and government to work together in taking EMS forward has been sought from the EMS Steering Committee (EMS SC) — an industry/community consultative committee established as an outcome of the Rural Industry EMS Forum held in Canberra on 14th March 2002.
The EMS SC reports directly to the Hon. Senator Judith Troeth. Since its establishment, the EMS SC has provided input into finalising Australia's National Framework for Environmental Management Systems in Agriculture and the EMS National Pilot Program. More recently the Committee has been providing advice to the EMS Implementation Working Group on the development of the EMS Implementation Plan.
Much of the advice from the EMS SC forms the basis for the partnership activities presented in Table 3. However, the EMS SC has also reviewed what it considers to be the key issues in the adoption of EMS by primary producers.
Key Issues for EMS Adoption
The EMS SC believes strongly that environmental management systems can deliver improved natural resource management and supports the implementation of practical, user-friendly, flexible systems by Australian primary producers. The Steering Committee recognises the following issues as critical to achieving this aim.
Cost/Benefit of EMS for Primary Producer
The major impediment to adoption of EMS by most primary producers is the lack of a demonstrable financial incentive. The costs (time and financial) associated with developing and implementing an EMS have been documented in various industry-funded projects, but there is little evidence to indicate that these costs might be offset by increased financial returns. However, these projects were early trial work and as such participants often began with undeveloped tools (workbooks) and were not delivered in a framework conducive to participants' recognition and reward. Robust data demonstrating an adequate financial return from implementation of an EMS across all industries will greatly assist its adoption. So also will word-of mouth from satisfied landholders who have identified wider EMS benefits, including use as a valuable management tool. The EMS National Pilot Program will help to quantify the benefits (including business efficiency gains) that accrue to producers once an EMS is established.
Paperwork
Many Australian primary producers have limited knowledge and experience in the use of structured business planning techniques. As a result, primary producers often have difficulty with the planning, review and reporting approach required by an EMS. Tools that facilitate the recording of data that primary producers generate and collect in the course of their day-to-day business operations should be a priority.
EMS links to catchments
Australian Government and State natural resource management programs are now increasingly implemented at catchment and sub-catchment level. Achieving natural resource management outcomes through EMS will be greatly enhanced through linking primary producer's management activities to catchment management targets. The link, with information exchange, will improve overall management effectiveness. It could also demonstrate compliance with national resource management efforts such as combating salinity, conserving bio-diversity or or managing on farm greenhouse gas emissions. This will heighten the potential for market recognition and reward for EMS compliant landholders.
EMS links to industry
Uptake and implementation of EMS on farm will be improved if strong linkages are developed between emerging environmental management programs and existing industry Quality Assurance and food safety systems. Similarly a whole of farm approach is considered more appropriate to deliver the desired environmental outcomes at a landscape scale where effective catchment linkages exist.
The need for consistency between industries in their approach to EMS is therefore paramount.
Given the costs associated with system development and maintenance, particularly auditing costs, systems should be structured to enable a single audit to address all aspects of Quality Assurance including the environment and food safety. Consideration should also be given to the costs borne by industry to develop and maintain such systems when there may be inadequate market drivers (consumer or producer demand). ª¥e role of certifying agencies, system owners and accreditation bodies are recognised in order to achieve the aim of a single audit.
Tiered approach to achieving an EMS
Experience with implementation of quality management systems on farm has shown that ISO 9000 was considered an inappropriate first step for primary producers. Successful QA models included a tiered approach, starting with simple requirements building to more rigorous systems. This approach allows primary producers to progress at their own pace and to a level that meets their personal and customers' needs. There is a strong belief that third party certified EMS, as with ISO 14001, represents too large and perhaps an unnecessary initial step for the majority of primary producers. Hence it is recommended that a tiered approach to achieving an EMS be adopted, and that this be once again consistent across industries.
Whilst a decision on the form of any tiered system should await the outcome of the pilots and further research, the MLA and GRDC have both completed projects, which have made recommendations for a similar tiered approach to EMS. A possible tiered approach could be summarised as follows:
Tier 1: This tier aims to raise awareness and interest in environmental issues and management systems.
- Some training in EMS to inform primary producers what EMS is about.
- Completion of self-assessment questionnaires.
- Single issue environmental monitoring.
- 'Due diligence' considerations of legal obligations.
Tier 2: This tier aims to take primary producers some way towards an auditable EMS, building on Tier 1.
- Development of EMS Implementation Plans.
- Multi-issue environmental monitoring.
- Adoption of industry Best Management Practice.
- Catchment goals to be assessed within the initial environmental review as the 'community standard' where available.
Tier 3: This tier will produce an ISO 14001 compliant EMS which is certified by 3rd party auditors such as those now accredited for QA, HACCP, and Organics.
Tier 4: This tier is an EMS to ISO 14001 level and which is audited by JAS-ANZ accredited auditors.
Industry targets
The EMSSC believes that the Implementation EMS Implementation Plan should contain targets relating to:
- agreement between industries in their approach and ¡®vision¡¯ for EMS to ensure consistency;
- agreement between industries or knowledge of what each industry is doing to develop and promote EMS; and
- understanding of market drivers and customer required environmental assurance/management systems.
Information exchange
An important component of the National Framework and EMS Implementation Plan is to ensure that there is adequate information exchange between the various stakeholders. This will not be an easy task given the number of stakeholders, the differing scales at which these stakeholders operate, and the need for cross-industry actions. Suitable processes should be implemented to facilitate information exchange and this could be a responsibility for the EMS SC. The lack of basic, local resource data for use by farmers is currently a limitation to adoption of environmental management systems.
EMS pilots
The EMS SC considers the EMS National Pilot Program will support the adoption of EMS by primary producers through:
- helping to quantify the benefits (e.g. marketing, business efficiency gains) that accrue to producers using an EMS; and
- development of tools that facilitate the application of an EMS and allow the day-to-day business of an enterprise to be integrated within the EMS.
The EMS SC considers it essential that the Rural R&D Corporations are aware of the projects being undertaken within the National Pilot Program and that links are made with these projects wherever possible and appropriate.
09 Jan 2010