This paper was written in response to a previous article written by Robert Gale and published in Eco-Management and Auditing. This paper argues that Gale misunderstood the Canadian environmental auditing guideline Z751, due to his interests in calling for a prescriptive environmental management systems (EMS) specification (i.e. a detailed model for the development of audit criteria). It also argues that the conclusion –that since Z751 is not an EMS specification it will not be used –is unsubstantiated. The analysis is based on a misunderstanding of the intent of Z751 and the role it plays. This article aims to consider Z751 within its specified framework: that of an environmental auditing tool which should be accompanied by other management tools. Copyright © 1995 John Wiley & Sons, Ltd and ERP Environment.