why Exxonmobil has chosen ISO 14001 Attestation and what it means

ExxonMobil has chosen to secure a corporate "Attestation" to demonstrate that it has implemented systems for environmental management worldwide that meet ISO requirements and to demonstrate that our self-declaration to conformity as permitted by the standard is judged credible by recognized knowledgeable third party assessors of ISO 14001.

Q1: Does OIMS meet all the requirements of ISO 14001?
A1: Yes and in key areas it exceeds ISO 14001.

It has been designed to meet the ISO 14001 requirements in all respects, and was verified to fulfill these requirements by Lloyd's Registered Quality Assurance Inc. (LRQA) in 1998 and again in 2001. In fact, we believe OIMS exceeds the requirements of ISO 14001 in the areas of management commitment/accountability, system assessment/continuous improvement, management of change, incident investigation/follow-up, and emergency preparedness. OIMS is used across all operations and organizations.

Q2: What does Attestation mean?
A2: It is an additional step beyond the self-certification allowed by ISO14001.

Some companies have well-designed environmental management systems which incorporate comprehensive assessment processes that predate the ISO 14001 Standard. ISO 14001 recognizes this and provides for companies to either self-certify (or self-declare) conformance to the standard or to seek third-party certification. Shortly after ISO 14001 was published, ExxonMobil measured its integrated environment, safety and health management system (OIMS) against the ISO standard and determined that it conformed.

We then took the additional step of having a third-party, LRQA, compare OIMS with ISO 14001, verify that OIMS meets all the requirements of ISO 14001, review the internal processes the company uses to assess conformance with OIMS and evaluate the integration of this management system into ongoing business activities.

LRQA completed its initial review in January 1998 for Exxon facilities. This process was repeated by LRQA in early 2001 and they subsequently provided an "Attestation that Exxon Mobil Corporation meets the requirements of ISO 14001 through OIMS and that OIMS has been implemented across the company." Lloyd's went beyond a statement of conformance and said, "We further believe ExxonMobil to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes."

Q3: What is the difference between attestation and certification?
A3: Actually, they are quite similar. Both include third party review resulting in a statement declaring conformance to ISO 14001 which covers management system design, content, broad implementation and integration into ongoing business activities. For attestation, Lloyd's Registered Quality Assurance focuses their assessment on the internal processes ExxonMobil uses to evaluate the suitability, adequacy and effectiveness of its integrated environmental, health and safety management system rather than directly evaluating the effectiveness of the system as is normally done for certification.

Every third year, Lloyd's undertakes a comprehensive assessment and validates the effectiveness of our management system by verifying ExxonMobil's own assessments against a physical verification by Lloyd's own assessors. They are free to verify against all major business functions and from a broad geographic and cultural perspective. Nine site verifications were made in 2001.

Annually, Lloyd's conducts a review at Corporate headquarters and the headquarters of one or two worldwide functional business units (Upstream and Downstream headquarters visited in summer 2002). The review assesses efforts to continually improve environmental management systems, management leadership and expectations, and check the frequency and quality of assessments completed during the prior year by the company against its assessment plans and standards. This interim review is intended to verify that ExxonMobil continues to meet the requirements of ISO 14001.

The major difference is that the attestation is acheived with fewer detailed assessments annually. Certification would assess at least the square root of the number of total ExxonMobil sites. The sampling could be as large as one third of all sites annually; the actual sampling frequency for corporate certification would be subject to the judgement of the third party assessor and could be subject to final review by the Registrar Accreditation Board. Attestation is more cost efficient without compromising the integrity of the assessment.

Q4: Why did ExxonMobil choose attestation versus certification to ISO 14001?
A4: Attestation can meet the expectations of our customers and others interested in our performance at significantly lower cost. In addition, many other benefits exist.

We believe the quality of assessment is enhanced. Our verification of the effectiveness of implementation is done by knowledgeable and trained personnel that have intimate knowledge of the operations being assessed. It is unlikely that many third party assessors  would have this same level of understanding of our operations or have a full appreciation of their complexity.

To assure independence, we use experienced and knowledgeable company employees, not reporting to the organization being assessed. The assessors are selected from line operations management and SH&E professionals. All have been trained in OIMS assessment techniques and each assessment team is carefully chosen to have an appropriate mix of skills, related operational background and prior assessment experience to meet the unique needs of a particular assessment. Of critical importance is the capability of the team to go beyond verification that a management system exists. We count upon them to evaluate effectiveness of implementation and to make judgements about an organization's capability to mitigate risk and to respond to unplanned operational circumstances.

It is important to note that our "external" assessments are primarily intended as a "cold eyes" review. Every manager has a personal responsibility to ensure OIMS is operating effectively and that requirements are met. Each operating organization conducts comprehensive self-assessments annually. The external assessment with experienced and trained personnel from outside the operating organization is conducted approximately every three years.

Finally, the valuable learning and sharing of sound practices which results from the way we staff the ExxonMobil external assessments allows operations managers to see sound practices being employed at facilities other than those under their direct responsibility. This increases the sharing of best practices throughout our facilities and helps to increase the quality of our performance.

Recognizing that others outside the company may prefer third party checks, we have taken the step to secure attestation. Attestation ensures that knowledgeable third party assessors verify the quality of our self certification and judge it to be comparable to a third party certification.

ISO 14001 allows both certification by third parties as well as self certification (or self-declaration) to the standard. Our customers and interested parties can be confident through Lloyd's attestation that OIMS fully meets the requirements of ISO 14001, that our internal assessment process is sound, that OIMS has been implemented by all ExxonMobil operations, and therefore that our self certification is valid when judged by recognized knowledgeable ISO 14001 assessors. With such a comprehensive and rigorous assessment process in place, overlaying this effort with additional third party audits would bring no additional value.

Q5: Wouldn't third parties be more objective and bring a broader perspective to the audits?
A5: The quality and objectivity of our assessors is beyond reproach Our corporate culture is driven by learning and improving. Third parties, because of their general unfamiliarity with our complex operations, would have great difficulty examining them in sufficient depth to bring any broader perspective. Experienced company personnel from operations other than those being assessed, given independence, can  typically meet or exceed the capabilities of third parties.

Q6: Will you periodically update the Attestation?
A6: Yes. Lloyd's attestation that OIMS meets the requirements of ISO 14001 is applicable for the next three years (until 2004).

Q7: Does ExxonMobil foresee a time when some of its facilities will be certified to ISO 14001?
A7: We have no plans for third-party certification at this time. Longer term, third-party certification will continue to be considered along with other alternatives to effectively achieve our business goals and give customers and interested parties confidence in our management systems.