UK

United Kingdom · Compliance, quality and safety · Lead (8-12 years)

Lead Environmental Management System Strategist

Here is the whole job, in plain words. What it is, what you decide, how you're judged, how people get here and where they go next. Then the part no course gives you: twelve AI tutors who learn your work.

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  • Experience bandLead (8-12 years)
  • Direct reports3-5 reports
  • Reports toEnvironmental Manager / Principal
  • UK framework levelUsually a manager, or the deepest specialist in a team

Also advertised as Environmental Programme Manager · Senior EMS Consultant (Internal) · Environmental Compliance Lead

Built on 43,079 real UK job descriptions we analysed · grounded in what real qualifications cover

Two short quizzes about you

1From this job to a course

The qualifications matched to this job

CMI Level 5 NVQ Diploma in Management and Leadership Chartered Management Institute · Level 5 · covers 1 of 10 standards
City & Guilds Level 5 Diploma in Leadership and Management City & Guilds Limited · Level 5 · covers 1 of 10 standards
City & Guilds Level 5 Award in Leadership and Management City & Guilds Limited · Level 5 · covers 1 of 10 standards
City & Guilds Level 5 Diploma in Principles of Leadership and Management City & Guilds Limited · Level 5 · covers 1 of 10 standards
City & Guilds Level 5 Certificate in Leadership and Management City & Guilds Limited · Level 5 · covers 1 of 10 standards
GQA Level 6 NVQ Diploma in Construction Site Management (Construction) GQA Qualifications Limited · Level 6 · covers 1 of 10 standards

Matched from the standards this job is measured against: a suggestion, not an official ruling.

The units you would start with

Manage Health and Safety in own area of responsibility CMI Level 5 NVQ Diploma in Management and Leadership
Improving and maintaining the organisation’s environmental performance City & Guilds Level 5 Diploma in Leadership and Management
Managing installation, commissioning and handover of retrofit works in the workplace GQA Level 6 NVQ Diploma in Construction Site Management (Construction)

The future skills this job leans on

Data Fluency turning numbers into a decision
Sustainability Fluency building care for people and planet into the work
Your Plan Illustration

Built for Lead Environmental Management System Strategist

3 units that map to this job, from the qualifications that cover it.

  1. Manage Health and Safety in own area of responsibility Chartered Management Institute · covers 1 of 10 standards Level 5
  2. Improving and maintaining the organisation’s environmental performance City & Guilds Limited · covers 1 of 10 standards Level 5
  3. Managing installation, commissioning and handover of retrofit works in the workplace GQA Qualifications Limited · covers 1 of 10 standards Level 6
These are the real units behind this job, in the order they rank for it. Nothing here is marked done, because this plan has not been started by anyone yet. Yours would fill in as you go.

2AI and this work

Will AI change your work as a Lead Environmental Management System Strategist?

Nobody can say exactly how. Here is what this job is being asked for next, and where to start.

The new skills this role is being asked for

  • Advanced Data Storytelling & Visualisation
  • Carbon Accounting & Net Zero Pathway Development
Why each one is rising

The future skills this job leans on

We'll only ever tell you what we can actually back up. No hype, no scare tactics.

What happens when you start

Next, a free account. We build your Lead Environmental Management System Strategist plan as you set up, starting with the free Data Fluency module. No card.

Your first Future Fluency module is free. After that, your AI tutor is £70 a month.

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Keep this read. One email with what AI is changing in this job, the new skills it asks for and where to start free. Nothing else follows unless you confirm your address.

3What this role really is

This job involves designing the environmental management system that keeps a site or business unit compliant and improves its sustainability. You draw up the blueprint and make sure operational teams follow it. A small team looks to you for guidance and direction.

4What you'd actually use

The tools this job runs on, and how well you'd need to know each one.

Intelex / Cority / Enablon (EHS Management Platforms) Advanced

Configuring workflows, building custom dashboards, managing user permissions, training end-users, troubleshooting data integration issues, and optimising platform use for EMS processes.

Enhesa / RegScan / C2P (Regulatory Intelligence Platforms) Advanced

Proactively setting up regulatory alerts, interpreting new legislation, assessing its impact on specific company operations, and ensuring the Legal Register is always current and actionable.

Microsoft Excel (with Power Query/Pivot) Advanced

Building complex data models for environmental performance tracking, performing ad-hoc analysis, and cleaning messy data from various sources before it goes into dashboards or reports.

Power BI / Tableau (Data Visualisation) Advanced

Creating interactive dashboards from scratch to track key environmental performance indicators (KPIs), visualising trends, and presenting insights to leadership and operational teams. You'll be telling stories with data.

Microsoft SharePoint / MS Teams (Document & Collaboration) Advanced

Designing SharePoint site structures for EMS documentation, managing document control workflows (versioning, approvals), setting up team collaboration spaces, and integrating with GRC systems for audit trails.

SAP S/4HANA (EHS Module) / Oracle NetSuite (ERP Interface) Intermediate

Working with IT to troubleshoot data discrepancies between the EHS platform and the ERP system, ensuring accurate material usage, waste generation, and other environmental data is captured and reported correctly.

5What you get to decide, and how that grows

Power in a job isn't your title. It's what you're allowed to decide. Here's how it grows as you move up.

The choiceComing in Where you are nowThe step above
EMS Programme Design Follows established templates, suggests minor improvements. Adapts existing programmes to new scenarios, proposes new procedures for routine tasks. Designs entirely new EMS programmes from scratch, including policies, procedures, and metrics for complex operational areas. Defines the strategic approach.
Budget Allocation (Environmental Projects) No authority. Submits requests to supervisor. Manages small project budgets up to £5,000, seeks approval for anything above. Full authority for project budgets up to £100,000 within their domain. Consults manager for larger capital expenditures or strategic investments.
Regulatory Interpretation & Impact Assessment Identifies relevant regulations based on guidance, asks for clarification on impact. Independently interprets routine regulations, assesses impact on specific processes, proposes compliance actions. Interprets complex, ambiguous regulations. Defines the company's compliance strategy in response to new legislation. Makes recommendations to Legal and senior leadership on significant regulatory shifts.
Staffing & Team Development None. Provides informal guidance to new joiners, contributes to peer feedback. Hires, manages, coaches, and develops 3-5 direct reports. Conducts performance reviews and makes promotion recommendations for their team. Defines team objectives.

6How you'll be judged

The scoreboard, and what is not on it. The hard targets, how often each is actually looked at, and the quiet signals that never reach a dashboard.

External Audit Performance
Number of minor and major non-conformances identified during external ISO 14001 certification audits for your assigned area.
Target · Achieve fewer than 3 minor non-conformances and zero major non-conformances per audit cycle.

In the last audit, your business unit had 2 minor non-conformances related to waste segregation, which is within target. A major non-conformance, like an unpermitted discharge, would be a significant issue.

Environmental Incident Reduction
Percentage reduction in reportable environmental incidents (e.g., spills, emissions exceedances) within your scope.
Target · Achieve a 10% year-over-year reduction in reportable incidents.

Last year, we had 20 reportable incidents. This year, if you've brought that down to 18, you're on track.

Corrective Action Closure Rate
Percentage of environmental corrective actions (CAPAs) closed on time and effectively.
Target · Maintain a 95% on-time closure rate for all assigned CAPAs, with 100% verified as effective.

If 19 out of 20 CAPAs were closed by their due date, and all 20 were confirmed to have actually fixed the problem, that's hitting the mark.

Waste Diversion Rate Improvement
Percentage increase in the amount of waste diverted from landfill (e.g., recycled, reused) within your operational scope.
Target · Increase waste diversion by 5% year-over-year.

If your site was diverting 70% of its waste last year, hitting 73.5% this year shows real progress.

Operational Integration of EMS
How well environmental management practices are embedded into daily operational routines, rather than being seen as 'extra' work.
  • Operations managers proactively consult you on process changes. Environmental procedures are routinely followed without prompting. You see evidence of environmental considerations in non-EHS team meetings. Feedback from site staff indicates they understand why they do environmental tasks, not just what to do.
Team Development & Mentorship
The growth and effectiveness of your direct reports, and your ability to guide them.
  • Your team members are taking on more complex tasks independently. They're asking insightful questions, not just simple 'how-to's. You're regularly providing constructive feedback and support. You've successfully mentored at least one L1/L2 team member to take on more responsibility or even promotion within 24 months.
Strategic Influence & Buy-in
Your ability to influence senior operational leaders and get their genuine buy-in for environmental initiatives.
  • You're invited to strategic planning meetings for your business unit. Your recommendations for environmental improvements are actively considered and often adopted. Senior leaders champion environmental initiatives you've proposed. They're allocating resources (people, budget) to your programmes based on your business case.
Proactive Regulatory Preparedness
How well you anticipate and prepare for changes in environmental legislation and regulatory scrutiny.
  • You're regularly updating the Legal Register and communicating upcoming changes before they become urgent. You've implemented new controls in response to anticipated regulations. During inspections, you're prepared for questions and can quickly produce required documentation, showing you're ahead of the curve.

7Would you like it

Both sides. What people enjoy, and what grinds them down.

What people enjoy
Building Robust Systems

You get a real kick out of designing a new environmental procedure that genuinely makes things clearer for everyone, or configuring an EHS platform to automate a previously manual task. You love seeing a well-oiled machine in action, especially when you've been the one to design it.

Spending an afternoon mapping out a new waste management process, including clear roles, responsibilities, and documentation steps, and then seeing it adopted successfully by the operations team.

Making a Tangible Environmental Impact

It's not just about compliance; you want to see real reductions in waste, energy use, or emissions. You're motivated by the numbers going in the right direction and knowing your work contributes to a greener outcome, not just a compliant one.

Presenting quarterly data showing a 10% reduction in water consumption at your site, knowing your water conservation programme played a key role.

Mentoring and Developing Others

You enjoy helping junior team members understand complex regulations or troubleshoot a data issue. Seeing them grow, take on more responsibility, and succeed under your guidance is genuinely rewarding for you.

Spending an hour walking through a tricky permit application with a newer team member, breaking it down into manageable steps, and then seeing them confidently submit it.

What frustrates people
  • The 'After-the-Fact' Notification: Finding out about a significant operational change or new equipment installation only after it's happened, meaning you're playing catch-up on permits or compliance.
  • Fighting 'Operational Drift': Training teams on new procedures, only for them to revert to old, non-compliant habits within a few months because it's 'quicker'.
  • Clunky EHS Software: Being stuck with an outdated or unintuitive EHS platform that creates more work for you and the operational teams than it saves.
  • Budget Battles: Constantly having to justify the financial return on environmental investments, even when they're clearly necessary for compliance or long-term sustainability.
  • Data Quality Issues: Spending hours cleaning up inconsistent or incomplete data from various sources before you can even begin to analyse it for reporting.
What this role does not give you
  • A quiet, solitary role where you just analyse data all day. This is highly interactive.
  • Instant gratification. Environmental improvements and cultural shifts take time, often years.
  • Direct authority over large operational teams. You'll lead through influence and expertise.
  • A 'set it and forget it' environment. Regulations change, operations evolve, and your systems need constant attention.

8Who you work with

This role directly shapes our environmental compliance posture and sustainability performance for a significant part of the business. You're not just reacting to problems; you're building the systems that prevent them, influencing operational decisions that affect our environmental footprint, and ultimately protecting our licence to operate. Your work directly contributes to our corporate ESG ratings and investor confidence, which, let's be honest, matters a lot these days.

Inside the business
  • Site Operations Managers (Production, Logistics)
  • Engineering and Maintenance Leads
  • Legal and Corporate Affairs
  • Procurement and Supply Chain
  • Health & Safety Leadership
  • ESG Reporting Team
Outside the business
  • Environmental Regulators (e.g., Environment Agency)
  • External ISO 14001 Auditors
  • Environmental Consultants
  • Local Community Groups (occasionally)

9What you need before you start

Not a wish list. The things you would be expected to already have.

  • Proven experience (8-12 years) in managing environmental compliance and EMS programmes, ideally within an industrial or manufacturing setting, or equivalent experience in a highly regulated environment.
  • Demonstrable experience in leading and conducting internal and external ISO 14001 audits, including managing non-conformances and driving corrective actions.
  • Solid track record of successfully implementing environmental improvement projects that delivered measurable results (e.g., waste reduction, energy efficiency).
  • Experience managing a small team or mentoring junior professionals, with a clear ability to guide and develop others.
  • Strong analytical skills, including advanced Excel and experience with data visualisation tools (Power BI/Tableau) to interpret complex environmental data.
  • Excellent communication and influencing skills, with a history of successfully engaging diverse stakeholders, including senior management and operational teams.
  • A deep understanding of UK environmental legislation and regulatory frameworks.

10What to practise next

Where the job is going, and what to do about it starting this week.

Advanced EHS Platform Configuration & Integration

EHS platforms are becoming more powerful and interconnected. Simply using them isn't enough; you'll need to be able to deeply configure them to meet evolving business needs, integrate them with other systems (like ERPs), and troubleshoot complex issues. This moves beyond 'super user' to 'system architect'.

API integrations for data exchange (e.g., with ERP · Advanced workflow automation design within the EHS · Custom report and dashboard development using plat · Data governance and quality within integrated syst · User acceptance testing (UAT) for new configuratio

  • This month: Identify one manual data entry task in your current EHS platform and research how it could be automated or integrated.
  • Next quarter: Work closely with IT on any EHS platform upgrades or new module implementations, focusing on the configuration side.
  • Month 4-6: Explore online training or vendor certifications for advanced configuration of our specific EHS platform.
  • Month 7-9: Propose a new integration between the EHS platform and another business system, outlining the benefits and challenges.

Quick win: Volunteer to be the 'power user' for any new EHS module or feature. Dig into the admin settings and documentation to understand how it works under the hood.

AI-Assisted Regulatory Analysis & Risk Prediction

The volume and complexity of environmental regulations are only increasing. AI tools are rapidly improving at summarising dense legal text and identifying patterns in operational data to predict risks. Those who can effectively use these tools will gain a significant competitive advantage.

Natural Language Processing (NLP) for regulatory t · Machine learning models for predictive analytics ( · Prompt engineering for effective AI interaction · Data privacy and security considerations when usin · Validation of AI outputs to avoid 'hallucinations'

  • This month: Experiment with public LLMs (e.g., ChatGPT, Claude) to summarise recent environmental news articles or regulatory updates.
  • Next quarter: Research AI tools specifically designed for regulatory intelligence or EHS risk prediction.
  • Month 4-6: Propose a pilot project to use AI for a specific regulatory analysis task or to predict a particular environmental risk.
  • Month 7-9: Take an introductory course on machine learning concepts to understand the basics of predictive modelling.

Quick win: Use AI to draft an initial summary of a complex internal environmental procedure. It won't be perfect, but it'll give you a head start and show you the potential.

11Staying current once you are in

What people here do to keep up
  • Regularly attend industry seminars, webinars, and conferences (e.g., IEMA events, Environment Analyst briefings) to stay current on regulatory changes and emerging best practices.
  • Actively participate in professional networks or forums for environmental professionals, sharing knowledge and learning from peers.
  • Seek out opportunities for cross-functional project leadership, especially those involving operational improvements with an environmental component.
  • Engage in continuous learning around data analytics and visualisation, perhaps through online courses or workshops on Power BI/Tableau.
  • Mentor junior colleagues within the team or through wider company programmes, honing your leadership and coaching skills.

12The rising capability

The rising capability

Zavmo analysis

What's rising in its place

This is where the work is heading, and the higher pay with it. Get fluent here and the shift stops being a threat and starts being your edge.

Advanced Data Storytelling & Visualisation

Essential for future readiness in this role.

  • Narrative structure for data presentations
  • Choosing the right chart type for your message
  • Principles of visual design for clarity and impact
  • Tailoring data stories for different audiences (e.
  • Using interactive dashboards to explore 'what if'

Carbon Accounting & Net Zero Pathway Development

Essential for future readiness in this role.

  • GHG Protocol (Scope 1, 2, 3 emissions)
  • Carbon footprint calculation methodologies
  • Science-Based Targets (SBTi)
  • Renewable energy procurement strategies
  • Life Cycle Assessment (LCA) for product/process em

13What you’ll use

What you’ll use

Skills this role draws on

Technical

  • ISO 14001 Management & Auditing
  • Environmental Compliance Reporting
  • Root Cause Analysis (RCA)
  • Sustainability Frameworks & ESG Reporting
  • Change Management Principles

14The pathway

The pathway

How you actually get there, here

How you become one varies far more by country than what one does. This is the UK route. Most people take one of these ways in; the right one depends on where you're starting from.

  1. 1

    Senior EMS Specialist (L3) at Zavmo

    3-5 years as a Senior Specialist

    Skills to master

    • Deepen your expertise in a specific environmental area (e.g., waste, air permits), lead complex internal audit programmes, successfully manage cross-functional environmental projects, and begin formally mentoring junior team members.

    You're ready to move on when

    • Consistently delivers complex environmental projects on time and within budget.
    • Recognised as a subject matter expert in at least one key environmental domain.
    • Demonstrates strong leadership potential and effectively guides junior colleagues.
    • Proactively identifies and solves systemic environmental issues, not just reactive fixes.
    • Successfully influences operational teams without direct authority.
  2. 2

    Environmental Consultant (Senior/Principal level)

    5-8 years in consulting

    Skills to master

    • Broaden your exposure to diverse industries and regulatory frameworks, develop strong client management and project delivery skills, and become adept at translating client needs into practical environmental solutions.

    You're ready to move on when

    • Experience managing multiple client projects simultaneously.
    • Strong track record of developing and delivering environmental solutions for various organisations.
    • Excellent stakeholder engagement and communication skills, often in high-pressure client environments.
    • Deep understanding of commercial aspects of environmental services.
  3. 3

    Environmental Engineer / Scientist in Industry

    6-10 years in engineering/science roles

    Skills to master

    • Gain hands-on experience in environmental impact assessments, pollution control technologies, site remediation, and process optimisation from an environmental perspective. Develop a strong understanding of industrial operations.

    You're ready to move on when

    • Proven experience designing or optimising industrial processes for environmental performance.
    • Strong technical background in specific environmental disciplines (e.g., air quality modelling, water treatment).
    • Experience working closely with operational and engineering teams to implement environmental controls.
    • Demonstrated ability to manage complex technical projects.

15Where this role leads

The long view: This work can lead into managing people or into technical specialism, with scope to shape environmental performance either way.

The ten Future Fluencies

Zavmo analysis

The credential is what you can do today. These are what keep you valuable.

A qualification proves you can do the job as it's defined today. These ten are what decide whether you're still the obvious person for it in five years. They're the capabilities employers are now writing into senior roles faster than people are learning them. Zavmo weaves them through whatever you study, so you come out with both: the credential and the fluency.

The highlighted ones are the Fluencies your role leans on hardest, from how Lead Environmental Management System Strategist is actually changing.

Where it leads

Roles this leads to

The record names a next step, but the catalogue has no page for it yet:

  • Environmental Manager / Principal (L5)

How you would learn this

One to one, on the work you already do

A tutor sets the task against your own job and marks the reasoning, at your pace. There is no cohort to fall behind.

A lesson from Manage Health and Safety in own area of responsibility, worked against Lead Environmental Management System Strategist.

Manage Health and Safety in own area of responsibility Level 5

Applied to your work in Lead Environmental Management System Strategist

This unit aims to enable learners to understand and manage health and safety within their own area of responsibility. Learners will gain knowledge of legal responsibilities, risk assessment, and risk minimisation strategies to promote a safe working environment.

How the thinking builds
  1. 1 Remember
  2. 2 Understand
  3. 3 Apply
  4. 4 Analyse
  5. 5 Evaluate
  6. 6 Create
An illustration of a Zavmo lesson, built from this role’s own route. The unit, its objective and every criterion above are the awarding body’s own words, not an example.

It is £70 a month, billed monthly. Your free first module is Future Fluency, and you can cancel any time.

See Your Progress Grow Illustration
Lead Environmental Management System Strategist
  • ISO 14001 Management & Auditing
  • Environmental Compliance Reporting
  • Root Cause Analysis (RCA)
  • Sustainability Frameworks & ESG Reporting
  • Change Management Principles
This is your Mind Palace on learn.zavmo.ai. Every skill above comes from this role's own record, not an example borrowed from another job. A node lights up when you evidence it, and what you build stays yours between jobs. That is the part a course cannot do.

16The detail, folded away

Everything else the record holds

The career branches in full, how AI is already showing up in the day-to-day, and the questions people ask about this job. Here when you want them, out of the way while you decide.

Where it leads next, rung by rung

Where it leads

The career path, and where it branches

Lead Environmental Management System Strategist is a start, not a ceiling. Each step below asks for new skills and hands back more autonomy.

  1. Environmental Manager / Principal (L5)

    3-5 years in the Lead EMS Strategist role

    This is a significant step up, moving from managing programmes and a small team to directing an entire environmental function or a larger site's EHS department. You'll own the overall strategy and budget.

    • Enterprise Risk Management Integrating environmental risks into broader corporate risk frameworks.
    • Advanced ESG Reporting Leading the development and assurance of corporate ESG reports.
    • Crisis Management Overseeing the environmental response to major incidents or regulatory challenges.
    • Stakeholder Engagement (External) Building relationships with key external bodies, industry associations, and potentially investors.
Working with AI on the job

Working with AI

Where AI is starting to help

Let's be real, a big chunk of environmental management involves sifting through data, writing reports, and keeping up with regulations. Imagine if you could cut down on those repetitive tasks, freeing you up to focus on the strategic stuff, the actual problem-solving, and leading your team. That's where AI comes in.

For a Lead EMS Strategist, AI isn't about replacing your expertise; it's about amplifying it. Think of it as having a super-efficient assistant that handles the grunt work, allowing you to focus on architecting robust systems, influencing stakeholders, and mentoring your team. It's about getting more done, more accurately, in less time.

Automated Report & Training Drafts

Use AI to generate the first draft of your monthly performance reports, internal audit summaries, or even site-specific toolbox talks on environmental topics. Just feed it the key data points and findings, and it'll handle the narrative, structure, and often, the formatting. This means less time staring at a blank page and more time reviewing and refining.

Regulatory Change Summarisation

Point an AI tool at new, dense environmental regulatory documents (e.g., from the Environment Agency or DEFRA). It can scan hundreds of pages and generate a concise summary of key changes, new obligations, and critical deadlines relevant to your specific industry and operations. No more slogging through endless legal jargon, just the actionable bits you need.

Intelligent Data Harvesting & Analysis

Deploy AI agents to automatically pull energy, water, and waste data from various sources – utility bills, smart meters, ERP systems (like SAP S/4HANA EHS module). This populates your EHS dashboards in near real-time, eliminating manual data entry and giving you instant insights into performance trends and potential issues. You'll spend less time collecting and more time interpreting.

Predictive Compliance Analytics

Use AI to analyse historical emissions, waste generation, and operational data patterns. It can then predict potential permit exceedances or compliance risks before they happen. This allows you to make proactive adjustments to production schedules, maintenance, or resource use, shifting your focus from reactive reporting to proactive risk mitigation. Imagine knowing a week in advance that you're trending towards a limit!

Common questions

Common questions

How do you become a Lead Environmental Management System Strategist?

Common routes in include Senior EMS Specialist at Zavmo (3-5 years as a Senior Specialist), Environmental Consultant (Senior/Principal level) (5-8 years in consulting) and Environmental Engineer / Scientist in Industry (6-10 years in engineering/science roles). Times vary with prior experience.

Where can a Lead Environmental Management System Strategist progress to?

This role can lead on to Environmental Manager / Principal (3-5 years in the Lead EMS Strategist role), depending on the skills you build.

What new skills matter most for a Lead Environmental Management System Strategist?

Increasingly, Advanced Data Storytelling & Visualisation and Carbon Accounting & Net Zero Pathway Development. These are the skills our record of this role lists as growing.

Free tools

Want a read on where you stand?

Three free tools, no account needed. Each one ends with a role, a level and a way in.

Read the Zavmo manifesto to understand how you will be taught Meet your tutors

Or try another one

17Where to go from here

Other roles at Level 5

Same depth of qualification, different job. Useful if the work appeals but this particular role does not.

 More jobs in compliance, quality and safety

Stay in the field you know and move sideways rather than up.
If you leave this industry

The skills built in this role transfer well. You could move into environmental consulting or specialise in ESG reporting for financial services. Some move into work for a regulatory body. Others move into operations management with a strong sustainability focus in other industrial sectors.

This role profile is © 2026 Growth Engineering Technologies Ltd. Built from UK occupational standards and regulated qualification data, and written for Zavmo.

You're not behind. You're right on time. The shift is only just beginning. Your role won't look the same in two years. Be the one who leads the change, not the one it happens to. Start my free Data Fluency module What happens next: a free account, then we build your plan as you set up. No card. Build your plan, see your roadmap and meet the twelve tutors matched to you. All free. When you're ready to start learning, it's £70 a month, billed monthly. Cancel any time and billing stops.