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ISO 14001 is an environmental management system design standard. Accredited private auditors (registrars) may be hired to periodically verify that a firm's management system conforms to the standard's requirements. Many influential companies, such as IBM, Ford and Toyota, are voluntarily implementing third-party verified management systems that conform to this standard, and encouraging their suppliers to follow suit. Thus, ISO 14001 may become a competitive requirement. Depending on the nature of registered facilities, the impact of adoption on management objectives, and the credibility of third party oversight, ISO 14001 may have a positive impact on environmental performance. As a result, state and federal environmental agencies are debating the use of ISO 14001 registration as a qualifier for regulatory flexibility. However, the standard lacks performance requirements. Firms are not even required to be in compliance with environmental law as a condition of registration. Thi