Introducing EMS Standards

Introducing EMS Standards
In September 1996, ISO and ISO were published. These standards allow a company to evaluate how it’s activities, products and services impact on the environment and how it’s environmental performance can be continuously improved. ISO 14001, in common with the EMAS Regulation is voluntary but differs from the Regulation in not requiring the implementing company to publish an environmental statement. It need only publish its environmental policy. To-date, approximately 200 Irish companies have been accredited to ISO TMS-EM01-C-01-01

Environmental Management System
Introducing EMS Standards Environmental Management System The part of the overall management system that includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy (ISO 14001:1996) A simpler definition of an EMS is “a management tool designed to help a company manage the environmental aspects of it’s operation”. TMS-EM01-C-01-01

ISO 14001 A management tool Drives performance improvement Is NOT an award for being “environmentally friendly” Starting baseline of environmental performance can vary Two companies operate side-by-side, manufacturing the same components, employing the same number of people for a number of years. Company A has attempted to improve its environmental performance while company B has breached environmental legislation and regulations. Provided that both companies commit to improving their environmental performance, (not specifying by how much), they can both be certified to ISO – in other words there are no performance criteria specified. TMS-EM01-C-01-01

Two Standards in Operation
Introducing EMS Standards Two Standards in Operation EMAS Regulation March 1993 ISO September 1996 Only six sites have been registered to EMAS in Ireland, as against over 200 sites accredited to ISO This is attributable to the requirement, in the case of EMAS, to publish an Environmental Statement detailing the environmental performance of the company. TMS-EM01-C-01-01

The Advantages of EMS Implementation
Introducing EMS Standards The Advantages of EMS Implementation Framework for Legislative and Regulatory Compliance Independent verification of commitment to the environment Cost Savings Customer Requirements Investment and Insurance Market Opportunities Corporate Image. Benefits to employees Improved relations with the local community IPC Requirement Most companies, once they become certified to ISO 14001, identify the fact that they have to keep up to date with current and proposed legislation as the greatest benefit of EMS implementation. For example, electronic companies might not be familiar with the WEEE Directive and its implications, unless they were compiling a Register of Environmental Legislation. Other advantages to EMS implementation are as follows: Cost savings, e.g. waste product recycling, energy usage reduction, etc. Customer requirements: a number of companies now require their supply base to be certified to an EMS standard, e.g. Microsoft and the printers of its manuals. Investment and insurance: investors in companies want some confidence that their investments are not going to depreciate as a result of a serious pollution incident, e.g. Exxon Valdez oil tanker in Alaska, which resulted in ~50% drop in the value of Exxon shares. Already in the UK, insurance companies are evaluating the EH&S risks of companies and setting the premiums on the basis of the level of risks the company is exposed to. There are obvious benefits to ‘badging’ your company with ISO 14001/EMAS: Your employees develop a greater sense of self-worth and are more motivated Your may gain a competitive advantage over your competitors Your relationship with the general community should improve Implementation of an EMS (albeit not necessarily formally certified) is a condition specified in all IPC licences. It would be advantageous to the IPC licencee to obtain ISO 14001, as this would ultimately result in the EPA waiving the audits of the company’s EMS. TMS-EM01-C-01-01

The Disadvantages of ISO 14001 Implementation
Introducing EMS Standards Does not identify the nature of progress in ‘continual improvement’ Does not require any form of independently verified environmental statement Organisations merely meet the requirements and class-leaders enjoy the same standard Identification of impacts difficult for service companies/SMEs Wording of standard is vague ISO is not prescriptive in that it does not specify the degree or extent to which companies should improve their environmental performance. This means that some companies (class leaders) will set themselves very difficult to achieve environmental objectives, whilst other companies may set themselves facile objectives. This is the major limitation of ISO The only publicly-available document is ISO is the company’s environmental policy. The absence of an independently verified environmental statement (which is required for EMAS) may give the impression that ISO is less rigorous than EMAS. Some companies avoid addressing supply side activities and/or eco design as part of their EMS because of the difficulties of dealing with these two environmental aspects. Finally SMEs and service companies may experience difficulties in identifying and monitoring/measuring their environmental impacts, due to lack of environmental expertise (SMEs) and/or tangible impacts (service companies). TMS-EM01-C-01-01

ISO 14001 Standard (Voluntary)
Introducing EMS Standards ISO Standard (Voluntary) Policy Continual Improvement in Environmental Performance Impacts on Environment Documented Procedures Training and Awareness Emergency Preparedness and Response Regular Audits by Certification Body The elements of an EMS. Whatever approach your company decides to take, an effective EMS will include: An assessment of the environmental aspects (potential impacts) of the company’s activities, products and services. An environmental policy and improvement programme with clearly defined objectives and targets. Clearly identified responsibilities for all employees. Written procedures to control activities that have a significant environmental impact. A controlled system of records. Regular auditing of the system to ensure that it is being operating correctly. Periodic management reviews to assess the performance and effectiveness of the system. TMS-EM01-C-01-01

The Interested Parties
Introducing EMS Standards The Interested Parties Competitors Regulators Investors/ Insurers Pressure Groups The Organisation Employees Marketplace Regulators : Local Authorities / EPA. Employees : the certification body will take a poor view of a company having practices, which are inimical to the best interests of the workforce (ref: OHSAS 18001). Public TMS-EM01-C-01-01

ISO and ISO 9001:2000 Policy, Commitment and Resources Responsibility and Authority System Structure and Document Control Training and Awareness Audits and Procedures for NC, CA and PA Records Management Reviews Annex B of ISO 9001:2000 details the links between ISO and ISO 9000:1994. ISO 9001:2000 was published towards the end of 2000 and has converged with ISO 14001, albeit with significantly different clause numbers. Both standards have as their theme the concept of continual improvement. TMS-EM01-C-01-01

The Core Elements of ISO 14001 Dr. Deming’s Principles for TQM TQM looks for continual improvement The PDCA (Plan, Do, Check, Act) cycle can be applied to any process. It is always represented as a circle since improvement is never ending! Plan Act Do Check TQM looks for continual improvement. The PDCA (Plan, Do, Check, Act) cycle can be applied to any process. It is always represented as a circle since improvement is never ending! TMS-EM01-C-01-01

Continual Improvement 4.2 Environmental Policy 4.3 Planning PLAN Environmental aspects Legal & other requirements Objectives & targets Env management programme 4.6 Management Review ACT 4.4 Implementation & DO Operation Structure & responsibility Training, awareness & competence Communication EMS Documentation Document control Operational control Emergency preparedness & response 4.5 Checking and CHECK Corrective Action Monitoring & measurement Non-conformance, corrective & preventative action Records EMS audit The EMS model is predicated on the company subscribing to the following principles: Principle 1 - Commitment and Policy The company should define its environmental policy and ensure commitment to its EMS. Principle 2 - Planning The company should develop a plan to fulfil its environmental policy. Principle 3 - Implementation For effective implementation, the company should develop the organisational structure, personnel and resource necessary to achieve its environmental policy, objectives and targets. Principle 4 - Measurement and Evaluation The company should measure, monitor and evaluate its environmental performance. Principle 5 - Review and Improvement The company should review and continually improve its environmental management system, with the objective of improving its overall environmental performance. With this in mind, the EMS is best viewed as a framework that should be continually monitored and periodically reviewed to provide effective direction for the company’s environmental activities, in response to changing internal and external factors. Every individual in the company must accept responsibility for environmental improvements and should be aware of the impact of his/her actions on the environmental performance of the company. TMS-EM01-C-01-01

Initial Environmental Review (IER)
Introducing EMS Standards Initial Environmental Review (IER) INPUTS Raw materials Energy Resource consumption Suppliers OUTPUTS Emissions Discharges Wastes Noise, etc. There is no mention of the IER in ISO or its Annex, but ISO gives a detailed description of how it should be implemented and what the benefits are. ISO “Environmental Management Systems - General Guidelines on Principles, Systems and Supporting Techniques” has been developed to provide additional guidance for companies on the design, development and maintenance of an EMS. It is only a guidance document and is not intended to be used for certification purposes. ISO is intended to provide the specification for a company’s EMS. ISO provides additional guidance and background information on the underlying principles, systems and supporting techniques necessary to develop an EMS. Processes TMS-EM01-C-01-01

Initial Environmental Review (IER)
Introducing EMS Standards Initial Environmental Review (IER) Advisable, but not assessable, should: Identify legislative and regulatory requirements Identify environmental aspects and associated impacts Evaluate performance Evaluate existing environmental management practices and procedures Investigate previous non-compliances TMS-EM01-C-01-01

Initial Environmental Review IER Identification of significant environmental impacts Register of Aspects managed by The company which implements ISO needs to demonstrate the key linkage between significant environmental aspects/impacts identified in the course of the IER and their management by means of an environmental objective and/or operational control (documented procedure). Example: a company has set itself an objective of reducing its waste packaging by 10% but may also have a documented procedure for its control (operational control). Setting Objectives/ Targets Management Programme Operational Control Documented Procedures and/or TMS-EM01-C-01-01

4.1 General Requirements Is there an EMS? Is it supported? TMS-EM01-C-01-01

4.2 Environmental Policy Relevant to activities, products Commitment to continual improvement and prevention of pollution Understood and implemented at all levels Commitment to comply with all relevant regulations and legislation Provides framework for setting and reviewing objectives and targets Publicly available The policy is the driver for implementing and improving the EMS so that a company can ultimately improve its environmental performance. The policy establishes an overall sense of direction and sets the principles of action for a company. It sets the goal as to the level of environmental responsibility and performance required of the company, against which all subsequent actions will be judged. The most important consideration is that the policy provides the framework for the setting and reviewing of objectives and targets. Quantification of these will come in the environmental management programme. TMS-EM01-C-01-01

4.3 Planning Aspects Environmental impacts evaluation & register controlled and uncontrolled emissions to atmosphere controlled and uncontrolled discharges to water toxic and non-toxic waste use of natural resources, raw materials and utilities noise, odour, dust , vibration, visual impact habitats, ecosystems, flora and fauna contaminated land Definition of an Environmental Aspect: The element of an organisation’s activities, products or services that can interact with the environment. A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact. The planning section of the standard requires the company to: establish a procedure to identify the environmental aspects of its operations; establish a procedure to identify legal and other requirements to which the company subscribes; establish and maintain documented environmental objectives and targets at each relevant function and level within the company; establish and maintain an environmental programme for achieving objectives and targets. TMS-EM01-C-01-01

4.3 Planning 4.3.1 Aspects (continued)
Introducing EMS Standards 4.3 Planning Aspects (continued) Normal, abnormal conditions Accidents, potential emergency situations Past, current, planned activities Direct and indirect All activities, products and services Update information Evaluate significance of impact (consider the law?) The identification of environmental aspects and the evaluation of associated environmental impacts is necessary to establish the current position of the implementing company in relation to its environmental performance. Direct aspects which the company can control such as noise, and indirect aspects i.e. aspects which the company can be expected to influence such as supply side activities must be taken into account, if deemed significant. Those aspects considered significant, i.e. those that have or can have a significant environmental impact, must then be addressed in setting the company’s environmental objectives. All environmental aspects of the company are identified as are all actual and potential positive and negative environmental impacts associated with each identified aspect. The significance of each impact must be evaluated by considering it’s scale, severity, probability of occurrence and it’s duration. The company must also take into account potential regulatory and legal exposure; the concerns of interested parties and the cost associated with mitigating the impact. Whereas adverse impacts such as contamination of air or rivers are commonly understood, it should also be recognised that environmental benefits may arise from activities, e.g. development projects could remediate land previously contaminated. The company needs to update the Register of Environmental Aspects on a regular basis, every 3, 6 or 12 months. The discussion pertaining to this update should ideally be minuted. TMS-EM01-C-01-01

4.3.2 Legal & other requirement
Introducing EMS Standards Legal & other requirement Register of Environmental Legislation Parent Company Corporate Policy Current and Draft EU Directives and Regulations Government Acts and Regulations Local authority/IPC licences Must periodically check compliance with legislation (Clause 4.5.1) Need to demonstrate understanding of legal obligations If companies use an outside agency to update their Register of Environmental Legislation, they must demonstrate that they understand how various pieces of legislation impact on their company and whether they are compliant with the legislation or not. On publication, Regulations are immediately applicable in Ireland. Directives need to be transposed into Irish law. TMS-EM01-C-01-01

4.3.3 Objectives and Targets
Introducing EMS Standards Referenced to legislative and regulatory requirements Consistent with environmental policy & continual improvement Linked to most significant aspects For each objective, set detailed performance targets ISO defines an environmental objective as “an overall environmental goal, arising from the environmental policy, that an organisation sets itself to achieve, and which is quantified where practicable”. An environmental target is defined as a “detailed performance requirement, quantified where practicable, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve these objectives”. In other words, the targets are lower-level goals, arising from, and summing towards the achievement of the objectives. Targets should be specific, measurable, achievable, realistic and trackable (SMART). Targets should have individually measurable environmental performance indicators (EPIs). Examples of environmental performance indicators that can be used to measure progress against objectives and targets include: Quantity of raw material or energy used. Quantity of emissions e.g. VOCs, CO2. Waste produced per tonne of finished product. Number of environmental incidents/accidents. Percentage of waste recycled. ISO on Environmental Performance Indicators should be consulted. TMS-EM01-C-01-01

4.3.4 Environmental Management Programme
Introducing EMS Standards Environmental Management Programme Environmental Management Programme including: detailed objectives and targets timeframe designated individuals The purpose of the environmental management programme is to ensure that the corporate environmental objectives and targets are achieved. The Environmental Management Programme should address schedules, resources and responsibilities for achieving the company’s environmental objectives and targets. Separate programmes must also be established to address the environmental management of new developments and new or modified activities, products or services. Because of the importance of the programme, it is recommended that a senior manager be nominated to ensure a co-ordinated and structured approach to its implementation. Normally, this role is undertaken by the management representative. Separate programmes will need to be established to manage new developments and new or modified processes or services. Such programmes should: · Identify and evaluate the potential impacts of such new developments and develop appropriate project environmental objectives; · Establish mechanisms to achieve those objectives; · Address the environmental aspects of changes as projects proceed; · Take corrective action, and assess its effectiveness. In this way, adverse impacts can be controlled and the planning and design process harnessed to provide opportunities to benefit the environment. TMS-EM01-C-01-01

4.4 Implementation & Operation 4.4.1 Structure & responsibility
Introducing EMS Standards 4.4 Implementation & Operation Structure & responsibility Roles are defined, documented, communicated Management to provide resources Nominate management representative Example structure for EMS roles and responsibilities: Role Responsibility Establish business strategy for EMS Managing Director, senior management Develop environmental policy Managing Director, Management Rep. Develop objectives and targets Department managers Co-ordinate management programme Management Representative Ensure legal compliance Operations managers, mgt. rep. Monitor overall EMS performance Management Representative Ensure continual improvement All managers Identify customers envir. interests Sales and marketing department Evaluate suppliers env. performance Purchasing department Comply with policy & EMS procedures All staff The Management Representative will have responsibility and authority for: Undertaking the environmental review. Implementing and maintaining the EMS to ISO or EMAS. Reporting EMS performance to senior management for review. Implementing continual improvement and managing new developments. TMS-EM01-C-01-01

4.4.2 Training, Awareness & Competence
Introducing EMS Standards Training, Awareness & Competence All staff should receive awareness training Appropriate training for personnel managing significant impacts Competence of contractors All employees should receive awareness training on: · the importance of conformance with the environmental policy and objectives and with the requirements of the EMS; · the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance; · their roles and responsibilities in achieving conformance with the environmental policy, objectives and procedures and with the requirements of the EMS, including emergency preparedness and response requirements; · the potential consequences of departure from specific operating procedures. Outside contractors will also be required to demonstrate that their employees have sufficient training with regard to environmental performance i.e. that they can perform the work in an “environmentally responsible manner”. All environmental training undertaken by company employees should be formally recorded in their personnel records. Typical of the environmental training undertaken by companies are the following: environmental legislation awareness training; environmental awareness training; hazardous waste training; preparedness and emergency response training; chemical handling and spillage control training. TMS-EM01-C-01-01

Communication Procedure for internal/external communication Responding to external queries about E.M.S. Record decision on external communications relating to environmental aspects It is important to emphasise that the company is only obliged to publicly disseminate its environmental policy under ISO It is not required to publish any information relating to its environmental performance. However, the enactment of the European Communities Act 1972 (Access to Information on the Environment) Regulations, 1998 and the requirement for IPC licensed companies to publish their environment performance will subject companies to increased public scrutiny in the future. TMS-EM01-C-01-01

4.4.4 Environmental Management Documentation
Introducing EMS Standards Environmental Management Documentation Initial Environmental Review (IER) Register of Environmental Aspects Register of Environmental Legislation Environmental Manual Environmental Procedures Manual (SOPs) Environmental Management Programme, Objectives, Targets Environmental Policy A typical environmental manual will be segmented in accordance with the clauses of ISO and will contain the following: · environmental policy; · key environmental roles, duties and responsibilities and organisational structure; · cross reference any related procedures in other parts of the company’s management system, such as quality or health and safety. It is recommended that the documentation associated with the environmental management programme and environmental objectives and targets be controlled independently of the environmental manual as the former needs to be regularly updated. TMS-EM01-C-01-01

EMS documentation Introducing EMS Standards Policy Objectives and Targets System Manual Aspects Legislation Register Register Procedures Work Instructions Records Procedural guidance will typically consist of two parts: 1. Generic procedures which are common to all environmental management systems and are essential to the successful implementation of the EMS. 2. Specific procedures which are a function of the complexity and size of the company and which mirror its environmental policy and objectives and the need to maintain operational control of its most significant aspects. A procedure is a set of directions or instructions for carrying out specific tasks or activities. Procedures should be drafted and implemented where their absence could result in an infringement of the EMS and a possible non-conformance in an environmentally critical situation, whether undertaken by company employees or contractors. TMS-EM01-C-01-01

Document Control Procedures to control documents identifiable, reviewed, revised & authorised of the current revision at the operating location removed if obsolete legible, dated, well ordered and retained for a specified period someone responsible for creation & modification ISO requires an organisation to establish and maintain procedures for the control of all their documents and data such as hard copy and/or electronic media, especially those relating to process control of their environmental activities. Indeed, where the term ‘documented procedure’ appears within ISO 14001, this requires the procedure to be established, documented, implemented and maintained. All documentation used by the organisation in support of its EMS must be controlled to ensure that: it is issued to the appropriate personnel it is revised and reissued as necessary all obsolete versions are removed from the point of use TMS-EM01-C-01-01

4.4.6 Operational Control Identify functions, activities and processes which affect or have potential to affect environment Documented procedures and work instructions Specify operating criteria Control of procurement and contracted activities Typical List of Procedures: Environmental incident/release investigation and reporting. Evaluation of new processes/materials. Integrity testing of waste chemical store. Environmental control of sub-contractors/vendors. Segregation and storage of drummed material/waste. Control of chemicals entering the premises. Guidelines for the arrival and unloading of bulk tankers. Guidelines for filling waste into drums. Minor chemical spillage. Empty drum management. Hazardous waste contractor selection and control. Obsolete equipment disposal. Transport. Control of MSDS Register. Boiler maintenance. Leak audit procedure. TMS-EM01-C-01-01

4.4.7 Emergency preparedness and response
Introducing EMS Standards Emergency preparedness and response Identify potential accidents Prevention and mitigation of associated impacts Periodically test procedures and if necessary review and revise procedures The Emergency Plan should include the following: Identification of potential accidents and emergencies. Identification of the person to take charge during the emergency. Details of actions to be taken by personnel during an emergency, including those actions to be taken by external personnel who are on the site or the emergency, such as contractors or visitors (who can be required, for example, to move to specified assembly points). Responsibility, authority and duties of personnel with specific roles during the emergency(e.g. fire-wardens, first-aid staff, toxic spillage specialists). Evacuation procedures. Identification and location of hazardous materials and emergency action required. Interface with external emergency services. Communication with statutory bodies. Communication with neighbours and the public. Protection of vital records and equipment. Availability of necessary information during the emergency e.g. plant layout drawing, hazardous materials data, procedures, work instructions and contact telephone numbers. TMS-EM01-C-01-01

Emergency Plan/Equipment
Introducing EMS Standards Emergency Plan/Equipment The emergency plan(s) should outline the actions to be taken when specified emergency situations arise Emergency equipment needs should be identified, and equipment should be provided in adequate quantity This should be tested at specific intervals for continuing operability Examples of Emergency Equipment include: Alarm systems. Emergency lighting and power. Means of escape. Safe refuges. Critical isolation valves, switches and cut-outs. Fire fighting equipment. First-aid equipment (including emergency showers, eye wash stations, etc.). Communication facilities. TMS-EM01-C-01-01

4.5 Checking & Corrective Action 4.5.1 Monitoring & Measurement
Introducing EMS Standards Checking & Corrective Action Monitoring & Measurement Procedures to monitor process parameters that affect environmental impacts Ensure reliability of data e.g. calibration of monitoring equipment Periodic evaluation of compliance with relevant regulations and legislation Typical monitoring and measurement activities include the following: Taking noise levels in neighbouring communities. Monitoring effluent parameters as per the effluent discharge/IPC licence conditions. Monitoring of air emissions per air emissions/IPC licence. Checking the annual consumption of natural gas in boilers. Checking that the segregation of various waste streams is appropriate. Confirming the environmental probity of environmentally critical suppliers. Monitoring the on-site activities of contractors. Establishing the suitability of product disposal instructions. Monitoring the efficacy of new processes or equipment. TMS-EM01-C-01-01

4.5.2 Non-conformance & Corrective & Preventive Action
Introducing EMS Standards Non-conformance & Corrective & Preventive Action Corrective/preventive action appropriate to magnitude of impact Resultant procedural changes to be implemented and recorded Results from: - internal and external audits, - complaints, breaches of regulations and legislation abatement plant breakdown breaches of policy or objectives. Technically not achieving an environmental objective is not a non-conformance. However, companies use the process to flag their non- achievement of an objective/target. TMS-EM01-C-01-01

Records Evidence of operation of system Filing, storage, maintenance Access and safeguards Retention times defined and recorded Typical records: Inspection, calibration and maintenance data. Environmental complaints. Monitoring records. Incidents reports. Correspondence with regulatory bodies. Employee training and communications. EMS audits and management reviews. TMS-EM01-C-01-01

4.5.4 Environmental Management Systems Audit
Introducing EMS Standards Environmental Management Systems Audit Based on environmental performance of activity concerned Audit plan Corrective action must get to root cause The audit programme and procedures should cover: · the activities and areas to be considered in audits; · the frequency of audits; · the responsibilities associated with managing and conducting audits; · the communication of audit results; · auditor competence; · audit methodology. Unlike quality management system audits, in which all of the activities of the company are given equal coverage, in EMS auditing, it is recommended to audit with greater depth, intensity or frequency, activities with the greatest potential to pollute or use natural resource. For example an in-house effluent treatment plant is likely to be audited more often than, for example, a warehouse. Companies should also consult the auditing standards within the ISO suite of standards, when preparing their audit plans. These are: - ISO 14010:1996, “Guidelines for Environmental Auditing - General Principles”. - ISO 14011:1996, “Guidelines for Environmental Auditing - Audit procedures - Auditing of Environmental Management Systems”. - ISO 14012:1996, “Guidelines for Environmental Auditing - Qualification criteria for Environmental Auditors”. TMS-EM01-C-01-01

4.6 Environmental Management System Review
Introducing EMS Standards 4.6 Environmental Management System Review Undertaken by Senior management Documented minutes Changes to policy and objectives Continued suitability of E.M.S. Concerns of relevant interested parties The following items will form the basis of the agenda for the meeting as appropriate: · Status of the Environmental Management Programme (Objectives & Targets) · Regulatory compliance · Legislative compliance · Environmental Complaints & Incidents · Environmental Non-Compliances · Internal and External Environmental Audit Reports · Status of Environmental Management System/Environmental Policy · Summary of Environmental Performance · Any Other Business TMS-EM01-C-01-01

Steps involved in EMAS Implementation
Introducing EMS Standards Steps involved in EMAS Implementation Define an Environmental Policy Carry out an Initial Environmental Review Define an Environmental Policy at corporate level As a first step, a company-wide environmental policy must be endorsed at the highest level of the implementing company. The policy is central to communicating the environmental priorities of the company to the general public and to other stakeholders. It must contain the following two central elements: - a commitment to comply with all relevant environmental legislation and regulations; - a commitment to continuous environmental improvement. The environmental policy must be written in clear concise easily understood language and must be available to the general public. Carry out an Initial Environmental Review The review which encompasses an identification of environmental aspects and the evaluation of associated environmental impacts, is necessary to establish the current position of the implementing company in relation to its environmental performance. Direct aspects which the company can control such as noise, and indirect aspects, i.e. aspects which the company can be expected to influence such as supply side activities must be taken into account, if deemed significant. Those aspects considered significant must then be addressed in setting the company’s environmental objectives. All environmental aspects of the company are identified as are all actual and potential positive and negative environmental impacts associated with each identified aspect. The significance of each impact must be evaluated by considering its scale, severity, probability of occurrence and its duration. The company must also take into account potential regulatory and legal exposure; the concerns of interested parties and the cost associated with mitigating the impact. The review of the company’s activities should consider: - emissions to air; releases to water; waste management; contamination of land; use of raw materials and natural resources; other local environmental and community issues; impact on habitats and ecosystems; indirect aspects such as supply side activities and product design; noise, odour, dust and vibrations. Normal and abnormal (including start-up and shut-down) conditions as well as accident or emergency situations should also be considered when assessing significant environment aspects. The company should also identify and interpret all of the environmental legislation which the company must comply with. All regulatory requirements to which the company subscribes to, including planning permissions, effluent discharge licences, air emissions and IPC licences must also be reviewed. TMS-EM01-C-01-01

Introducing EMS Standards Steps involved in EMAS Implementation Set environmental objectives Establish an Environmental Management System Set Environmental Objectives Objectives should be specific and mirror the overall goals of the environmental policy. They should be derived from the evaluation of the significance of environmental impacts which was previously carried out. Measurable targets should be set to achieve these objectives, within a specified time frame, using quantifiable environmental indicators which can be used as the basis for a subsequent environmental evaluation system. A company should consider the use of best available technology where it is economically viable, cost effective and judged appropriate. The environmental management programme should address schedules, resources and responsibilities for achieving the company’s environmental objectives and targets, as well as the methods and time-scale by which they are achieved. It is crucial to the successful implementation of an environmental management system. Establish an Environmental Management System (EMS) The Environmental Management System establishes operating procedures and controls (including the organisational structure, responsibilities, practices and resources) to ensure the successful implementation of the environmental policy and management programme. It can be based on the requirements specified in EMAS or it can use the elements of a recognised environmental management system standard such as ISO 14001, to meet the corresponding requirements of EMAS. Topics that need to be addressed include: - structure and responsibility; - EMS documentation; - communication; - training; - management review. TMS-EM01-C-01-01

Introducing EMS Standards Steps involved in EMAS Implementation Set up Internal Auditing Programme Prepare an Environmental Statement Set up Internal Auditing Programme Annex II and Article 4 of the EMAS Regulation sets out the requirements for an environmental audit. The Regulation defines the ‘environmental audit’ as a management tool comprising a systematic, documented, periodic and objective evaluation of the performance of the organisation, management system and processes designed to protect the environment. The aim of the audit is twofold: (i) to exercise management control over activities in the company which may have an impact on the environment; (ii) to assess compliance with the company environmental policy. This internal audit can be conducted either by auditors employed by the company or by third party auditors (e.g. consultants) acting on its behalf. In both cases, the audit has to be conducted according to rules which are set out in the Regulation. These rules cover: · objectives and scope of audit; · organisation and resources including training of auditors; · planning and preparation of audit; · conducting the audit; · reporting audit findings; · post-audit activities. When deciding the auditing frequency (which must not exceed three years), the company should take account of: - the nature, scale and complexity of the on-site activities; - nature and scale of emissions, waste generated and energy consumed and, interaction with the environment; - significance of problems detected during audit; - history of environmental problems at the site. Prepare an Environmental Statement The preparation of the Environmental Statement is the chief feature which distinguishes the EMAS Regulation from ISO The Environmental Statement is formulated to be read and understood by the general public and because of this it must be written in a concise and comprehensible form. To ensure that the information contained therein is correct, it must also be validated by Accredited Environmental Verifiers. A full Environmental Statement is required for each audit cycle - which may be up to a maximum of three years. A simplified statement (covering a summary of pollution figures etc.) must be prepared annually in the intervening years, unless the site is small or there have been few significant changes since the last statement. TMS-EM01-C-01-01

Introducing EMS Standards Steps involved in EMAS Implementation External Audit and Validation of the Environmental Statement External Audit and Validation of the Environmental Statement Accredited Environmental Verifiers (who must be independent of the site’s auditor) have two roles: - to verify compliance with EMAS requirements; and - to validate the environmental statement. In their verification role Accredited Environmental Verifiers must check: - whether the environmental policy has been drafted and if it meets the requirements of Article 3 and Annex I; - whether an environmental management system and programme are in place and functioning at the site and whether they comply with the relevant requirements in Annex I; - whether the environmental review and audit are carried out in accordance with the relevant requirements in Annex I and II; - whether the data and information in the environmental statement are reliable and whether the statement adequately covers all the significant environmental issues of relevance to the site. In their validation role, Accredited Environmental Verifiers have to validate the environmental statement. The external verifiers must confirm that the environmental statement is representative of the status of the company vis a vis its environmental policy, objectives, management programme, procedures and overall EMS. To enable the verifiers to confirm that the environmental statement is appropriate to the implementing company they will need to: - gain an understanding of the organisation of the site, including all activities; - examine internal EMS documentation, particularly audit documentation; - interview site management and personnel. The company’s internal audit process must be comprehensive to the point that the Accredited Environmental Verifiers are able to: - verify compliance with all of the EMAS requirements; - verify completeness, fairness, reliability, etc. of data in the Environmental Statement. The Accredited Environmental Verifiers should verify the accuracy and comprehensiveness of the internal audit - rather than duplicate the audit activities which have already been undertaken. The Accredited Environmental Verifiers will submit a report to the senior management of the company being assessed, which will specify: (a) any deviations from the specific requirements of the EMAS Regulation; (b) any deficiencies in the environmental review or internal audit methodology ; (c) points of disagreement with the draft environmental statement, together with recommendations on suitable amendments or additions to the environmental statement. If satisfied, the Accredited Environmental Verifiers will validate the statement. If the statement needs to be changed, validation will be withheld subject to the changes being made. Any deficiencies in the EMS will necessitate the withholding of validation by the Accredited Environmental Verifiers until the shortcomings have been corrected. Only accredited EMAS verifiers can validate the implementing company’s Environmental Statement. TMS-EM01-C-01-01

Schematic diagram of key steps in EMAS
Introducing EMS Standards 1 Company environmental policy Accredited environmental verifiers 2 Initial environmental review Accreditation System 3 Environmental programme 6 Environmental Objectives 4 Environmental management system Maximum audit cycle three years 8a Verification Each member state has to establish a system for the accreditation of independent environmental verifiers (who may be individual or organisations) and for the supervision of their activities. The National Accreditation Board (NAB) fulfils this role in Ireland and has approved the first Accredited Environmental Verifier. Environmental verifiers accredited in one member state may perform verification activities in another member state, subject to prior approval. The competent body of each member state, which in the case of Ireland is the National Accreditation Board (NAB), will, at six monthly intervals, send a list of Accredited Environmental Verifiers to the European Union, which will be published in the Official Journal of the European Commission. · Annex III of the Regulation sets out general criteria concerning the accreditation of environmental verifiers and the function of the verifier. Accreditation criteria for environmental verifiers shall include the following: - competent in relation to the functions within the accredited scope; - maintained records on the qualifications, training and experience of the relevant personnel; - independent and impartial; - documented procedures for the verification requirements of the Regulation. Verifiers complying with EN 45012, Articles 4 and 5 comply with these requirements. If the Environmental Management System (EMS) is based on a recognised international standard, such as ISO 14001, and has been assessed by an approved certification body, those parts which meet the EMAS requirements do not have to be separately validated. The frequency of the external audit cycle will depend on the nature and risks associated with the activities on the site, but it cannot extend beyond three years. 5 Environmental Audit 8b Validation 7 Environmental statement TMS-EM01-C-01-01

Site’s Environmental Statement Introducing EMS Standards A description of the site's activities An assessment of all the significant environmental issues A summary of figures on pollution emissions, waste production, consumption of raw material, energy, water and noise Company's environmental policy and site's programme and management system Deadline for the next statement Name of the accredited environmental verifier APPLICATION FOR REGISTRATION When a site is ready to apply for registration under the scheme (or ready to submit a validated environmental statement on a subsequent occasion), the following information must be provided to the National Accreditation Board (NAB): Name of company; Name and location of the site; Brief description of the activities at the site; Name and address of the accredited environmental verifier who validated the environmental statement; Deadline for submission of the next validated environmental statement. The following details must also be included in the application: A brief description of the environmental management system; A description of the auditing programme established for the site; The validated environmental statement. The competent body in Ireland to whom the environmental statement is submitted is the National Accreditation Board (NAB). Site registration occurs once the competent body receives a validated environmental statement and any applicable registration fee levied, and is satisfied that the site meets all of the Regulation’s requirements, which includes complying with all relevant environmental legislation. DE-REGISTRATION De-registration can occur if: a company fails to submit a validated environmental statement and registration fee within 3 months of the deadline specified in its previous statement; NAB becomes aware that the site is no longer compliant with the requirements of the Regulation; a regulatory body informs NAB that the site is no longer in compliance with relevant environmental legislation. The culmination of the EU scheme is the award of a site based logo. The logo which lists the company’s sites registered to the scheme can be used by companies on their headed note paper, brochures, etc. to publicise and promote their involvement in the scheme. It cannot, however, be used in product advertising or on products or their packaging. In the case of a site already accredited to ISO 14001, a verifier must: · confirm that the certification is issued under an approved accreditation scheme; · check that the scope of the certification covers the same geographic area as the scope for the EMAS registration; · ensure that the implementation of ISO 14001/EN ISO has covered all items listed in Annex 1 C and D; · check that the environmental aspects and significant environmental impacts identified by the site address the effects listed in Annex 1 B3, where appropriate; · confirm that the site has made provision for legal compliance; · check that the frequency of the audit cycle is three years or less and that the audit deals with environmental performance; · ensure that the data in the environmental statement are a fair representation of the site’s performance and that the statement meets the requirements of Article 5. The National Accreditation Board (NAB), in association with the Environmental Protection Agency (EPA) has produced a document which outlines the convergence between the environmental statement requirements of the EMAS Regulation and the Annual Environmental Report (AER) requirements of IPC licences. An update of the EMAS Regulation will be carried out in 2000, which is likely to shown increased convergence with ISO and the inclusion of service companies within the scope of the Regulation. TMS-EM01-C-01-01

Revision of EMAS Regulation 761/2001
Introducing EMS Standards Revision of EMAS Regulation 761/2001 Scope broadened to all types of companies Incorporates ISO as the management system Company can use separate reports extracted from body of validated information Annual validation of environmental statement New logo The long-awaited revision to the EU Eco-Management and Audit Scheme (EMAS) is finally at an end, following agreement on the text of the revised Regulation by the European Council of Ministers and the European Parliament. Publication of the Regulation in the European Commission’s Official Journal is expected in February, after which it will need to be implemented by each Member State. Ireland expects to implement the scheme in mid 2001. The scope of EMAS has been broadened to allow all types of organisations from any economic sector to participate. The revised scheme incorporates ISO as the management system; no longer will EMAS and ISO be seen as competing systems. EMAS is the logical next step for those organisations with ISO who want to build their environmental credibility further and seek greater recognition and for IPC licensed companies. Public reporting of environmental performance sends out a clear message – it says you’re proud of what you’re doing and are happy to demonstrate this, and involve anyone who’s interested. It isn’t just a public relations exercise. The right information targeted at the right interest groups can be a tool for developing positive partnerships, particularly when the information is backed up by independent validation. The old scheme required one environmental statement to meet the needs of all interested parties. Greater flexibility has been introduced into the new scheme to allow different bodies of information, badged with the EMAS logo, to be targeted at different stakeholder groups. No longer will organisations be bound by ‘one report suits all’ – separate reports extracted from a body of validated information can be targeted at regulators, financial institutions, shareholders, suppliers, customers and the community. Dialogue with stakeholders before writing the statement should help to ensure a more responsive audience. In addition, statements and reports can be produced in electronic format. Validation of changes to the environmental statement will need to be undertaken on an annual basis, except in exceptional circumstances for small organisations. One of the most innovative aspects of the revised scheme is how participants are able to use the revised EMAS logo. The cumbersome statement of participation has been removed. The logo can be used to illustrate that the organisation is registered, and that information about the organisation or its products, services or activities has been validated. It is the opportunity to use the logo with validated information that is potentially the most innovative, especially to validate ‘green claims’. The logo may be used on used on vehicle fleets, organisation web sites and company reports. In addition, it may also be used on adverts for the organisation, or for its products/services, provided that the information that the logo is used with, has been validated as being reliable, credible and relevant. The logo may not be used directly on products for fear of being confused with the European Eco-Label – which confirms that the product has superior environmental credentials from other similar product types. EMAS gives a seal of reliability on the information that is presented. TMS-EM01-C-01-01

Revision of EMAS Regulation 761/2001
Introducing EMS Standards Revision of EMAS Regulation 761/2001 Corporate EMAS Registration for multi-site organisations Breach of legislation will not necessarily lead to de-registration The revision creates an opportunity for corporate EMAS registration for multi-site organisations under one certificate. This ties EMAS more closely to ISO in terms of the ‘entity’ that can be registered. However, multi-site organisations will need to demonstrate to the verifier that the Regulation’s requirements are being met at all of their ‘sites’ and the systems and procedures for aggregating and collating data for the corporate environmental statement are sound, reliable and effective. In addition, data for significant environmental impacts at each site will need to be identified clearly in the environmental statement. The heart of the old EMAS is environmental performance improvement. This has been retained in the new Regulation. Participants must give a commitment to continual improvement and, through the environmental statement, report on their results. The scheme recognises that improvement may not occur across the whole of an organisation’s sphere of activities simultaneously, but the environmental improvement programme should be targeted at its most significant environmental aspects. Environmental audits are also required to address environmental performance, not simply whether the right documented procedures are in place. One of the key steps in the EMAS registration process is the check on legal compliance made by the ‘competent body’ with the environmental regulators. This feature is retained to ensure that, if there are problems of legal compliance, the regulators are consulted as to whether the organisation’s registration should be refused, suspended or accepted. The EMAS guidance note on breaches is currently being reviewed and is likely to be more closely aligned with the Environmental Protection Agency’s enforcement and prosecution policy. Prosecution by the regulator does not necessarily result in suspension from the EMAS register – it will depend on the circumstances of a breach and the way in which the organisation reacts to such a situation. The role of the regulators gives added credibility to EMAS registered sites compared to organisations certified to ISO TMS-EM01-C-01-01

Comparison between ISO 14001 and EMAS
Introducing EMS Standards ISSUE ISO EMAS Environmental Policy   Environmental Aspects  Called effects Legislative and other requirements   Objectives and targets   Programme   Define responsibilities   Identify training needs   Procedures for internal communications  X External communications Consider processes Give information for significant aspects to public Prepare Statement X  Environmental Statement validated X  Maintain documented systems   Procedures for controlling all required docs.  X Records to be kept   Conduct audits  At least every three years In the case of a site already accredited to ISO 14001, a verifier must: confirm that the certification is issued under an approved accreditation scheme; check that the scope of the certification covers the same geographic area as the scope for the EMAS registration; ensure that the implementation of ISO 14001/EN ISO has covered all items listed in Annex 1 C and D; check that the environmental aspects and significant environmental impacts identified by the site address the effects listed in Annex 1 B3, where appropriate; confirm that the site has made provision for legal compliance; check that the frequency of the audit cycle is three years or less and that the audit deals with environmental performance; ensure that the data in the environmental statement are a fair representation of the site’s performance and that the statement meets the requirements of Article 5. The National Accreditation Board (NAB), in association with the Environmental Protection Agency (EPA) has produced a document which outlines the convergence between the environmental statement requirements of the EMAS Regulation and the Annual Environmental Report (AER) requirements of IPC licencees. An update of the EMAS Regulation was carried out in 2000, which showed increased convergence with ISO and the inclusion of service companies within the scope of the Regulation. TMS-EM01-C-01-01

EMS Assessment Process Assessment Team Initial Assessment Documentation Main Assessment Report & Certificate The ISO audit is broken down into three components: The Initial Assessment Documentation Review Main Assessment TMS-EM01-C-01-01

EMS Assessment Team Industry knowledge Environmental knowledge Technical Management System Licensed Lead assessor Institute of Environmental Management and Assessment (IEMA) International Register of Certified Auditors (IRCA) The team of auditors from the certification body will contain at least one auditor with specific knowledge of the industry, and its environmental aspects/impacts and controls. In addition, one of the other team members will be a management system expert, i.e. have a comprehensive knowledge of the ISO standard. At a minimum, the certification auditors will be licenced EMS lead auditors, preferably under the IEMA scheme. TMS-EM01-C-01-01

Initial Assessment Introducing EMS Standards Does the EMS address all elements of ISO 14001? Are planned arrangements implemented and effective? Is the EMS based on the evaluation and management of significant impacts? Is the EMS capable of delivering regulatory compliance and continual improvement? Can reliance be placed on the internal EMS audits? Are all of the clauses of ISO 14001, Clause 4.1 – 4.6 addressed by the company’s EMS? Are the SOPs that the company drafted properly implemented and working? Does the Register of Aspects actually identify and prioritise the company’s most significant environmental aspects and associated impacts? Does the EMS identify the company’s regulatory and legislative requirements and how compliant it is with these? Does the management programme, objectives and targets deliver continual improvement? Are the company’s internal auditors adequately trained and capable of conducting and reporting a competent environmental audit? TMS-EM01-C-01-01

Documentation Review Certification Body takes documentation from company for assessment The following EMS documentation is reviewed by the certification company: Initial Environmental Review (IER). Register of Environmental Aspects. Register of Environmental Legislation (including licences). Environmental Policy. Environmental Manual. Environmental Procedures. Management Programme, Objectives, Targets. TMS-EM01-C-01-01

Main Assessment Introducing EMS Standards Evaluation of: compliance with documented EMS management Commitment to EMS environmental Performance Improvement regulatory compliance staff awareness and training Assessment output: non-conformance Reports (NCRs) observations recommendation for certification TMS-EM01-C-01-01

Introducing EMS Standards

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