1. 1 ETIV - EMAS Technical Implementation and Verification 1 Project ETIV – EMAS TECHNICAL IMPLEMENTATION AND VERIFICATION Prepared by: Module 6 Environmental Review

2. 2 ETIV - EMAS Technical Implementation and Verification 2 This project has been funded with support from the European Commission. This publication reflects the views only of the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein. Module 6 Environmental Review

3. 3 ETIV - EMAS Technical Implementation and Verification 3 Objectives The following Module is aimed at providing the student of EMAS with an insight into the preparation of an integral Environmental Review of a company’s activities at a particular location, according to the Annex Vll of Regulation (EC) No 761/2001 Module 6 Environmental Review

4. 4 ETIV - EMAS Technical Implementation and Verification 4 Main steps of an Environmental Management System (EMS) Module 6 Environmental Review

5. 5 ETIV - EMAS Technical Implementation and Verification 5 Environmental Review Starting point for implementing of an EMS Allows the identification of all environmental aspects of the organisation’s activities, products and services, methods to assess these, its legal and regulatory framework and existing environmental management practices and procedures Used to inform and to revise the environmental policy and help to set environmental objectives Module 6 Environmental Review

6. 6 ETIV - EMAS Technical Implementation and Verification 6 Principal Requirements of an EMAS Environmental Review Perform a technical (input-output) analysis of the organisation Identify environmental aspects related to past, current or future operations Make a legal compliance assessment Evaluate the existing management practices Include the description of the following components of a specific company: - objectives and phases - description of the organisation, its history, location, operational processes, management - environmental aspects (direct and indirect) - significant aspects - significance assessment criteria Module 6 Environmental Review

7. 7 ETIV - EMAS Technical Implementation and Verification 7 Step by step approach Identify the environmental aspects involved Define the criteria which are of significance for the company’s environmental performance in terms of European legislation Identify those environmental aspects that are related to these significance criteria Module 6 Environmental Review

8. 8 ETIV - EMAS Technical Implementation and Verification 8 Data Collection & Assessment Data collection procedures should include the following points: Environmental indicators Basic data Data sources Conversion factors, if necessary Frequency of determining indicators Responsibility for collecting data Module 6 Environmental Review

9. 9 ETIV - EMAS Technical Implementation and Verification 9 Data Collection & Assessment The Collection of Data will concern, among other issues: Power production and distribution Water consumption Natural resources consumption (including raw materials) Polluting emissions Waste management Emission of noise Check of possible use and contamination of the soil Emergency management Indirect environmental aspects, such as the use of products and of services by users and consumers. Module 6 Environmental Review

10. 10 ETIV - EMAS Technical Implementation and Verification 10 Data Collection & Assessment The process of evaluation will particularly concern: The definition of the criteria, in order to evaluate the relevance of impacts The list of the most significant environmental aspects The choice of proper indicators which will provide for an accurate and transparent evaluation of the organization and will enable easy temporal and territorial comparisons The level of environmental efficiency of the activities realized in the company, using proper environmental indicators for every environmental aspect which has been considered. The individualization of the areas for the environmental performances, from a technical and managerial point of view Module 6 Environmental Review

11. 11 ETIV - EMAS Technical Implementation and Verification 11 Module 6 Environmental Review

12. 12 ETIV - EMAS Technical Implementation and Verification 12 Assessment Subject & Phases (Screening) The Environmental Review shall include effects arising, or likely to arise, as consequences of: normal operating conditions; abnormal operating conditions; incidents, accidents and potential emergency situations; past activities, current activities and planned activities. Module 6 Environmental Review

13. 13 ETIV - EMAS Technical Implementation and Verification 13 Assessment Subject & Phases (Screening) The Organisation: History, Location, Operation, Management Planning the process of the environmental review Gaining Corporate commitment Planning and assigning responsibilities Module 6 Environmental Review

14. 14 ETIV - EMAS Technical Implementation and Verification 14 Environmental Aspects (Scoping) Module 6 Environmental Review

15. 15 ETIV - EMAS Technical Implementation and Verification 15 Relevant legislative regulations, laws and policies Legal documents like permits, licences Organisational records and documents Organisational policies, procedures, charts Existing environmental policies Consumption and monitoring data, relevant contracts Inventories Material flow Maps and surveys of site Emergency plans Health and Safety procedures Incidents reports Stakeholder analysis (if available) Decide how to record this information (sample) Module 6 Environmental Review Environmental Aspects (Scoping) – Documents to consider

16. 16 ETIV - EMAS Technical Implementation and Verification 16 The impacts identification should include: emission to atmosphere; releases to water; waste management; soil pollution; use of water, fuels and energy and of the other natural sources; load by heat energy, noise, odour, dust, vibration, and radiation; impacts on the specific part of the environment Sources of the significant impacts (environmental aspects) in the organisation might be and are not limited to: emissions to the Atmosphere (energetic, technology and transport); releases to Water (wastewater - technologic, sewage, rain and cooling, contaminated water pumped at the remedial works); waste Management (by-products and waste disposal sites) Module 6 Environmental Review Environmental Aspects (Scoping)

17. 17 ETIV - EMAS Technical Implementation and Verification 17 Direct environmental aspects are associated with activities, products and services of the organisation itself, over which organisation has direct management control Module 6 Environmental Review Direct Environmental Aspects

18. 18 ETIV - EMAS Technical Implementation and Verification 18 Site, Footprint Raw Materials, Energy Product life cycle assessment Emissions, Releases, Disposal, Contamination Material Flow & Recycling Transport Module 6 Environmental Review Environmental Aspects over which an organisation has control

19. 19 ETIV - EMAS Technical Implementation and Verification 19 Receptors include all components and aspects of the surrounding environment that could be directly and indirectly damaged by any production and non-production Activity, like: air, water, soil, landscape, cultural and archaeological aspects, ecology and biota (biodiversity), noise and vibration Module 6 Environmental Review Environmental Aspects - Receptors

20. 20 ETIV - EMAS Technical Implementation and Verification 20 Main steps may involve: Assessment of Ambient Air Quality. Characterisation of Stack Emission and Pollution Load Studies. Fugitive emissions and work zone Air Quality Studies. Performance evaluation of Pollution Control Systems. Boiler Efficiency/Incinerator Efficiency. Micro-Meteorological data generation in respect of temperature, humidity, solar radiation, wind speed, wind direction, rainfall etc. Study of Gaseous Pollutants, Organic Solvents, Pesticides and Metallic Constituents and other Toxic Chemicals in Air, including PAH. Particle size distribution, respirable dust and dust fall rate studies. Data generation for EIA related studies Module 6 Environmental Review Environmental Aspects - Air

21. 21 ETIV - EMAS Technical Implementation and Verification 21 Main steps may involve: Analyse raw and treated water to assess suitability of water for specific end uses (domestic, irrigation, construction, potable, recreation and industrial applications) Mineral water analysis and sourcing Domestic and trade waste water for conformity to relevant standards for discharging Performance evaluation of water and effluent treatment plants, water purification equipment and storage vessels Flow measurement and total discharge of canals, streams and rivers etc. Ground water studies which include hydro geological survey, water availability, water use-pattern, water evaporation rates etc. Consultancy services in the areas of waste water treatment and pollution abatement. Module 6 Environmental Review Environmental Aspects - Water

22. 22 ETIV - EMAS Technical Implementation and Verification 22 Main steps may involve: Soil testing for physical and chemical analysis for engineering, agriculture and horticulture applications Test for heavy metals, pesticides and soil microbes Soil reclamation, salinity studies and its remedial measures Suitability of soil for types of crops Characterisation of wastes and hazard identification Incineration studies Toxicity waste behaviour and its contribution to ground water Handling and disposal of waste. Suitability of waste for land-fill or composting. Module 6 Environmental Review Environmental Aspects - Soil

23. 23 ETIV - EMAS Technical Implementation and Verification 23 Creation of industrial ecosystems: maximising use of recycled materials in production, optimising use of materials and embedded energy, minimising waste generation, and re- evaluating "wastes" as raw material for other processes or companies. Balancing organisations input and output to natural ecosystem capacity Dematerialization of industrial output Improving the metabolic pathways of production processes and materials use Systemic patterns of energy use Policy alignment with a long-term perspective of company’s management system evolution Module 6 Environmental Review Environmental Aspects – Ecology/Biodiversity

24. 24 ETIV - EMAS Technical Implementation and Verification 24 Landscape planning design project and management includes: Urban Design Landscape Design and Implementation Landscape Appraisal and Visual Impact Assessment: Landscape Planning: careful planning of existing landscape resources and the establishment of new sites for housing, industry, recreation and wildlife Historic Landscape Research and Restoration: The assessment, analysis, conservation, refurbishment and design of Historic Landscapes require sensitive and specialist expertise. Module 6 Environmental Review Environmental Aspects – Landscape Visual

25. 25 ETIV - EMAS Technical Implementation and Verification 25 The cultural heritage aspects include: Historical buildings and structures Archaeological sites and structures Palaeo-ontological sites Other cultural features Other cultural features are items of antiquities in very varied forms Module 6 Environmental Review Environmental Aspects – Culture/Archaeology

26. 26 ETIV - EMAS Technical Implementation and Verification 26 The Environmental Review should include : Description of noise-vibration generating production processes Identification of sensitive receptors in the vicinity (type and distance from organisation) Sound-vibration proofing methods planned or implemented inside and outside the organisation; Noise-vibration emissions at the site boundary and at sensitive receptors Company’s monitoring systems and frequency Attachments: Prior environmental audits or investigations, Site map, Site layout, Thematic maps, Noise and vibration level measurements, Local Environmental law applicable Module 6 Environmental Review Environmental Aspects – Noise/Vibration

27. 27 ETIV - EMAS Technical Implementation and Verification 27 Within the process of identifying stakeholders, social auditing Provides new approaches to the underlined and the growing importance of systematic stakeholder dialogue Social auditing is a means of measuring an organisation's/ company’s social impact and ethical behaviour in relation to its aims and those of its stakeholders Module 6 Environmental Review Environmental Aspects – Stakeholders

28. 28 ETIV - EMAS Technical Implementation and Verification 28 Indirect environmental aspects arise from activities, services and products, over which organisation has no or limited control on their impact on the environment. For non-industrial organisations, such as local authorities and financial institutions, it is essential that they also consider the environmental aspects associated with their core activities. An inventory limited to the environmental aspects of an organisations site and facilities is insufficient. Module 6 Environmental Review Indirect Environmental Aspects

29. 29 ETIV - EMAS Technical Implementation and Verification 29 The main objectives of indirect environmental effects include: Product related issues (design, development, packaging, transportation, use and waste recovery) Financial issues: capital investments, loans, insurance services New markets issues Choice and composition of services Administration and planning decisions Product range compositions Environmental performance and practices of contractors, subcontractors and suppliers Module 6 Environmental Review Indirect Environmental Aspects

30. 30 ETIV - EMAS Technical Implementation and Verification 30 Environmental Accounting (EA) is a method for evaluating the true environmental costs of operating a business, so these costs can be considered in business decisions. Environmental costs should include: costs of resources in production, cost of resources in general business operations, waste treatment and disposal costs, and in some situations: cost of a poor environmental reputation, environmental risk insurance premiums. Module 6 Environmental Review Indirect Environmental Aspects – Financial Issues

31. 31 ETIV - EMAS Technical Implementation and Verification 31 Environmental Taxes (ET) are one of the tools of financial management Module 6 Environmental Review Problems of ETBenefits of ET It is difficult to set taxes at a level which reflect the real environmental cost of an activity or product Some kinds of environmental taxes (for example, emissions taxes) have been shown to produce measurable results If there is no alternative to a resource (say a fuel) higher costs shift the burden to the consumer. This discourages consumption of the resource but may not lead to cleaner production It is difficult to direct the revenue from an ET directly towards renewing the correct resource - frequently the revenue simply goes into a general fund. However, directing the revenue very specifically may limit government policy options Proponents of green taxes argue that employment can be created, resource use optimised and pollution reduced by increasing taxes on resource use and decreasing income taxes Environmental taxes can damage the competitive advantage of a national industry unless a tax benefit is directed to eco-efficient enterprises in the same industry

32. 32 ETIV - EMAS Technical Implementation and Verification 32 With the objectives of addressing the conflict between protection of the environment and economic competitiveness by turning environmental concern into competitive advantage, the 5th European Action Programme included new economic and fiscal tools such as eco-labelling, EMAS and the proposed EU environmental taxation. The four categories of market- based instruments identified are: charges and levies; fiscal incentives; state subvention (or subsidy) systems; environmental auditing Module 6 Environmental Review Indirect Environmental Aspects – New Markets

33. 33 ETIV - EMAS Technical Implementation and Verification 33 The importance of moving beyond the production process is particularly relevant in the context of service industries. In the service sector, it is generally the case that direct, site-based impacts are minimal and the most significant impacts are associated with the policies or service 'products', so call indirect impact. Example: A bank has direct environmental impacts through heating, lighting, transportation, office equipment and paper use (so-called 'corporate ecology'), the indirect impact of its products - its loans and investment portfolios, or 'product ecology' - is likely to be by orders of magnitude more significant. Module 6 Environmental Review Indirect Environmental Aspects – Services

34. 34 ETIV - EMAS Technical Implementation and Verification 34 Through their various roles and tasks, committees and administrations make decisions and agree on various plans with a number of consequences for the environment. Planning is an important part of environmental management. For the company’s environmental performance it includes: environmental impact classification; legal and other requirements; identification of the main objectives and targets; environmental management programme; control/monitoring of its implementation and operation Module 6 Environmental Review Indirect Environmental Aspects – Administration/Planning

35. 35 ETIV - EMAS Technical Implementation and Verification 35 A study-project of environmental performance of contractors comprises principal phases: Formulation of environmental management concept for the contractors. Preparation of an environmental management policy and its implementations. Final testing in case companies according to the result of policy implementation. Completion of the environmental management system. Marketing of the EMSA to the contractors. Module 6 Environmental Review Indirect Environmental Aspects – Contractors

36. 36 ETIV - EMAS Technical Implementation and Verification 36 The main direction of internal environmental policy establishes objectives for the internal environmental strategy located in the following areas (integrated management within the indirect environmental aspect issues): Employee’s involvement Green Procurement Transportation Dissemination Module 6 Environmental Review Indirect Environmental Aspects – Management

37. 37 ETIV - EMAS Technical Implementation and Verification 37 Significant environmental effect: environmental aspect of an organisation activity that carries the potential to cause environmental harm on the global, regional, and local environment and population Environmental aspect - an element of an organisations activities, products or services that can affect the environment, Environmental impact - changes to the environment, whether adverse or beneficial, that result from the organisations activities, products or services Evaluation criteria - has to be comprehensive, capable of independent checking, reproducible, and made publicly available Module 6 Environmental Review Significant Aspects – Key concepts

38. 38 ETIV - EMAS Technical Implementation and Verification 38 EMAS recommends four steps for the identification and evaluation of significant environmental aspects: 1. Select an activity, product or service large enough for meaningful examination and small enough to be sufficiently understood 2. Identify direct and indirect environmental aspects of the activity, product or service, i.e. how does it interact with the environment? – Annex VI of the Regulation and the guidance provide some useful ideas. 3. Identify environmental impacts, considering actual and potential, positive and negative impacts associated with each aspect. 4. Evaluate significance of impacts Module 6 Environmental Review Significant Aspects – Key concepts

39. 39 ETIV - EMAS Technical Implementation and Verification 39 The most important tool to manage and to estimate the existing data on significant aspects of the company’s environmental performance is the use of Indicators which provide a numerical basis for evaluation of environmental performance, including the significance of environmental impacts. Module 6 Environmental Review Significant Aspects – Existing Data

40. 40 ETIV - EMAS Technical Implementation and Verification 40 Apart from the use as an internal instrument for measuring significant aspects of the company’s environmental performance, other possible applications for environmental indicators are: Benchmarking - Comparing your environmental performance with other organisations Internal communication - Illustrated performance indicators provide feedback to employees on the results of their efforts, and are therefore a valuable instrument for internal communication External communication - Data-supported reporting is the best way to gain the trust of public administrations, neighbours and environmental groups Module 6 Environmental Review Significant Aspects – Existing Data

41. 41 ETIV - EMAS Technical Implementation and Verification 41 Monitoring and measurement is about controlling the significant environmental aspects of the organisation Three specific tasks shall be addressed under the Monitoring and Measurement section of the regulation: Track the performance of the EMS with respect to the significant environmental aspects (documented procedure, records) Ensure accurate and reproducible measurements through maintenance and calibration of monitoring equipment (records); Evaluate regularly compliance with relevant environmental laws and regulations (documented procedure). Module 6 Environmental Review Significant Aspects – Regulated Activities

42. 42 ETIV - EMAS Technical Implementation and Verification 42 Balance of material and energy flows is the creation of a system where all material and energy flows going through the production are taken in account The balance is based on the law of conservation of mass and energy, i.e.: the quantity of substances and energy entering the company must leave the company or must be accumulated within the company Inputs and outputs of substances and energy are given in physical units (for example in kg, t, GJ) and apply always to a particular selected time period (year, month etc.) The environmental accounting attaches to the identified material and energy flows their monetary values, which has a substantial importance for a correct determination of environmental costs with respect to the significant impact. Module 6 Environmental Review Significant Aspects – Material Flow

43. 43 ETIV - EMAS Technical Implementation and Verification 43 Stakeholder groups are critical to the success of EMAS as a market instrument; but in order to fulfil their respective roles in relation to EMAS, they must: firstly, have access to appropriate information; secondly, be convinced of the legitimacy and credibility of the EMAS process. Public Environmental Reporting (PER) - also referred to as Corporate Environmental Reporting - is a method by which businesses report on their environmental progress to shareholders. Module 6 Environmental Review Significant Aspects – Stakeholders/Customers

44. 44 ETIV - EMAS Technical Implementation and Verification 44 The evaluation should consider the following criteria: the scale of impact on the environment the severity of the impact on the environment the scale and frequency of impact accumulation aspect of impact the probability of occurrence the duration of impact on the environment potential regulatory and legal exposure difficulty of changing the impact effect of change on other activities and processes concerns of interested parties and interaction effect on the public image of the company, stakeholders Module 6 Environmental Review Significant Assessment Criteria

45. 45 ETIV - EMAS Technical Implementation and Verification 45 Classification of Environmental Aspects shall include: (a) emissions to atmosphere; (b) discharges to water or sewers; (c) solid and other wastes, particularly hazardous wastes; (d) contaminated of land; (e) use of land, water, fuels and energy, and other natural resources; (f) discharge of thermal energy, noise, odour, dust, vibration and visual impact; (g) effects on specific parts of the environment and ecosystems. Module 6 Environmental Review

46. 46 ETIV - EMAS Technical Implementation and Verification 46 Classification of Environmental Aspects shall include effects arising, or likely to arise, as consequence of: (1) normal operating conditions; (2) abnormal operating conditions; (3) incidents, accidents and potential emergency situations; (4) past activities, current activities and planned activities." Module 6 Environmental Review

47. 47 ETIV - EMAS Technical Implementation and Verification 47 In relation to the type of business activity or branch of industry the organisaton belongs to, this procedure consists of four stages: (1) screening of all issues and activities; (2) testing of significance/analysing effect risk; (a) identifying environmental effects; (b) testing each effort for its significance; (3) prioritisation of effects (into improvement, control and further analysis actions). Module 6 Environmental Review Type & Location of Business/Industry

48. 48 ETIV - EMAS Technical Implementation and Verification 48 In relation to the location of the organisations, the procedure reveal following significance criteria: extent of existing economic, social and environmental stress, in affected areas; direction of changes to base-line area conditions; nature, order of magnitude, geographic extent and reversibility / duration of changes; regulatory and institutional capacity to implement measures on the site. Module 6 Environmental Review Type & Location of Business/Industry

49. 49 ETIV - EMAS Technical Implementation and Verification 49 Each branch of industry should be provided with necessary legislation updates and regulation on significant environmental assessment to ensure that companies are kept aware of any forthcoming legislation that will impact the business The updates of legislation must be reviewed by the environmental representative and assessed to determine if any requirements or changes are applicable to the company The organisations own register should then be updated accordingly Module 6 Environmental Review Legislation

50. 50 ETIV - EMAS Technical Implementation and Verification 50 Severity is one of the significance assessment criteria that reflect the potentiality, power, weighing, scale or degree of the capacity of the environmental impact According to the logic consideration a combination of the ‘frequency’ with which the environment is affected by that activity and the ‘severity’ of the effect when it does occur provides the basis for general understanding of the degree of significant environmental impact. Thus, the significance of an environmental effect increases proportionately with the frequency and severity. Module 6 Environmental Review Severity

51. 51 ETIV - EMAS Technical Implementation and Verification 51 The severity of an effect can be determined by considering a number of components, including: Proximity to a regulatory standard. Environmental impact (against recognised damage). Significance and extent of the receptor (e.g. local, national or global damage). Longevity and reversibility of the effect. Sensitivity of the public and press to the effect. Sustainability of an effect. Module 6 Environmental Review Severity

52. 52 ETIV - EMAS Technical Implementation and Verification 52 Scale is a main factor in determining the type of environmental measures and processes to use for the management of a particular potential impact. Frequency as a criterion of significance reflects the repeated in time occurrence of the significant damages to the environment from various types of activities and considers the necessity of systematic (frequent) protective measures called to prevent those events occur. Frequency is a systematic category and based in the areas, such as quantitative measurement related to the activities, health and safety. Module 6 Environmental Review Scale/Frequency

53. 53 ETIV - EMAS Technical Implementation and Verification 53 Environmental assessment significance are directed toward the general purpose of protecting the environment. Usually this means preventing and minimising adverse impacts on individual environmental components and its cumulative effect. Cumulative effects are addressed by aggregating individual effects (i.e. parts to whole). The role of environmental management is to control cumulative impacts. Module 6 Environmental Review Accumulation

54. 54 ETIV - EMAS Technical Implementation and Verification 54 Criteria of interaction within significant assessment criteria consider a multiple level of activities that affect the significance of environmental impact. Each level of interaction has its own influence over the procedure of the assessment. From the point of nature of the influence of criterion of interaction on significance assessment there are following types of interaction: Interaction between the people is the basic level of interactive activities. Interaction within the company of industrial or non-industrial sector of economy itself created the second level of interactive activities Module 6 Environmental Review Interaction

55. 55 ETIV - EMAS Technical Implementation and Verification 55 The third level of relation concludes the interaction between the companies: that belong to the same branch of industry; that located in the same area; that produce the same types of pollutions; that damages the same type of natural receptors; that use the same natural resources for production cycle; etc. As a sub-level of the third type of relation is interaction between different companies that belong to different industries, located in different areas, produce different type of pollutions, damaged different receptors, use different resources for their production, etc. The fourth level of communication is the interaction between industries within the governmental level. The fifth level includes the interaction of the global scale between the different countries, groups of the countries, multinational companies, and continents. Module 6 Environmental Review Interaction

56. 56 ETIV - EMAS Technical Implementation and Verification 56 To approach stakeholders’ objectives in environmental impact assessment company needs to: Evaluate the consequences of inaccurate recording of financial data Recognise, complete and interpret complex business documents and understand their interrelationships Evaluate the significance of the final accounts to different groups of stakeholders Explain why ratios change over time and how this affects different groups of stakeholder Draw conclusions about the financial performance of the business based on your use and understanding of a range of financial data; Justify changes to business practices to achieve required cash flow and budget requirements. Module 6 Environmental Review Stakeholders

57. 57 ETIV - EMAS Technical Implementation and Verification 57 Significant Risk Assessment includes: 1. Identification of significant risk must ensure that all significant risks are captured 2. Risk analysis 3. Risk evaluation 4. Risk treatment 5. Risk monitoring and risk review Module 6 Environmental Review Risks

58. 58 ETIV - EMAS Technical Implementation and Verification 58 There are three sides to environmental risk which a company must consider: Risks to the environment from manufacturing processes arising from normal routine process releases into the environment or from accidents or incidents which give rise to loss of containment and consequent release into the environment. Risks associated with purchase or inheritance of a contaminated site. Risks from the environment on a business arising from such problems as extreme weather conditions or long term environmental changes, for example, greenhouse effect and climate Module 6 Environmental Review Risks