Environmental Management Systems (EMS)

What is an environmental management ? (EM) It is aimed at reducing the impact of

human activity to such a degree that environmental harm and nuisance as well as
legal liability are minimised. Certified EMSs are not compulsory but an PPC affected
company is expected to have some form of EMS. Some companies are now
integrating their EMS with their Health and Safety and Quality systems into an
integrated System.

Advantages of EMS

 Shows an organisation how to incorporate environmental control into

management

 Gives external verification to third parties that EM is being implemented –

particularly important if the need for an EMS is driven by supply chain
pressure

 Should protect the environment

 Avoids environmental mistakes that may involve civil or criminal liabilities

 Cost saving from reduced consumption of energy and raw material and waste
disposal

 Cost saving by anticipating future legislation

 Motivation of the workforce

 Market edge and PR

 Better relationship with planners and regulators such as the EA or LA

particularly important for IPC and IPPC authorised companies

What is an Environmental Management System

The documented organisational structure, responsibilities, procedures, processes and

resources required for implementing environmental management. Essentially it shows
the company recognises that it has an impact on the environment, has identified the
key area where these impacts arise and is taking steps to minimise them by setting
objectives and targets. These all needs to be documented in a way that can be verified
by a third party- i.e. the organisation that provided certification.

Three types
1. BS EN ISO 14001

2. Eco-management and Audit. (EC Regulation 1836/93 EMAS) The EC

regulation which goes further than ISO

3. BS8555 launched 2003 (only for small and medium sized companies)

BS EN ISO 14001

ISO 14000 series launched in 1996, renamed BS EN ISO 14001in the UK in 1997 as
it replaced the BS 7750 and revised in 2001 to bring it more in line with the qualirt
standard ISO9000.

The standard sets the specification for a EMS " to support environmental protection
and prevention of pollution in balance with socio-economic needs” “ it enables the
organisation to establish and assess the effectiveness of procedures to set an
environmental policy and objectives, achieve compliance with them and demonstrate
such compliance to others. “

ISO 14004 provides guidance on the environmental management techniques.

ISO 14001

What is it

1 Is generic - it applies equally to a hospital or factory (EMAS to industrial sites

only)
It is applicable to all types of organisation whether manufacturing or service
providing. When deciding to implement it the company has to decide whether to go
from head office down to site level or to start one site at a time. The first gives you
consistency but the second is initially easier.

2 It does not establish absolute requirements for environmental

performance beyond

i. Procedures to ensure Compliance with legislation and regulations

ii. Commitment to continuous improvement in environmental terms

3 It is a management tool and not a regulatory device. So two different

organisations carrying out similar activities but with different environmental
performance may still comply with the requirements.

4 pro-active (an anticipatory/preventative approach)

5 voluntary (but requires rules to be followed)

6 ongoing - seeking continuous improvement

7 Systems based with documented procedure.

8 It requires the environmental policy and objectives to be publicly available.

EMAS also requires a certified and publicly available Environmental Statement

Structure of the EMS to ISO 14001

4.2 Policy

This should be appropriate to the nature, scale and environmental impacts of its
activities, products or services.

Include a commitment to continuous improvement and prevention of pollution

Include a commitment to comply with relevant legislation

Provide a framework for the setting of objectives and targets

Should be documented, implemented, maintained and communicated to all employees

Available to the public

4.3 Planning

4.3.1 Aspects and Impacts

The organisation shall establish and maintain a procedure to identify the

environmental aspects and the significant impacts of it’s operations

The contents and level of detail will depend on the company. These to include:-

Controlled and uncontrolled releases to atmosphere

Controlled and uncontrolled releases to water
Solid and other waste
Contamination of land
Use of land, water, fuels, and energy and other natural resources
Noise, vibration, dust, odour and visual impact

Need to examine effects on specific part of the environment including ecosystems.

Should include normal and abnormal operations; past current and future activities;
emergencies and accidents.

ISO14004 gives guidance on assessing aspects and impacts. Aspects being any
element of the organisations’ activities, products or services (APS) that can interact
with the environment. Impacts being any change in the environment, whether
beneficial or detrimental, wholly or partly resulting from the organisations’ APSs.

It suggests you look at activities, products and services within the organisation and
assess the aspects and impacts of each in a series of “blocks” to make it easier.

A major current problem is deciding whether an effect is significant. You can refer to
authorisations, sector guidance notes, waste transfer notes, etc. You should assess on
a basis of

 Is the aspect controlled by legislation or policy

 Is it sensitive

 Does it have heavy financial implications

 Is there an element of environmental risk attached to it.

i How likely something is to occur that would be harmful

ii How severe the environmental damage would be

4.3.2 Legal and other requirements
The organisation shall establish and maintain a procedure to identify those which
apply

A register should be established and maintained for all relevant legislation,

regulations and codes to practice. Register should include a list of the National and
International regulatory requirements appropriate to the organisations’ processes,
details of relevant Codes of practice. Summary of the regulatory requirement and how
they apply to the organisation. Can compile this by using a process data sheet and
assessing inputs outputs and emission, including noise and dust, odour etc including
the relevant legislation.

4.3.3 Objectives and Targets

These to be set after considering legal requirements, significant environmental

aspects and impacts and financial and business requirements. They should be
consistent with the policy

The objectives must be realistic and achievable. For example could be to recycle 50%
of all solvent waste within six months, or install photocopiers that can do double
sided copies as the old ones wear out, or reduce the volume of effluent discharged by
20% within a year.

The objectives should be based on the environmental policy, it's register of effects,
the views of interested parties, the costs and resources for implementation.

4.3.4 EM Programme

A programme should be set up to achieve the objectives and targets, should include
designation of responsibility, means and time frame
4.4 Implementation and Operation

4.4.1 Structure and Responsibility

Roles, Responsibilities and Authorities to be defined, documented and

communicated. Resources to be allocated

4.4.2 Training

All personnel whose work has a significant impact on the environment to receive
appropriate training

4.4.3 Communication

Both internal and external

4.4.4 EMS Documentation

EMS manual to be set up and describe elements of the EMS

4.4.5 Document Control

Location, review, distribution and storage procedures to be established

4.4.6 Operational Control

Control significant activities, provide procedures to avoid a breach of policy or

targets

4.4.7 Emergency preparedness and response

Establish and maintain response procedures, ensuring they are reviewed and tested.
4.5 Checking and Corrective Action

4.5.1 Monitoring and Measurement

The organisation shall establish and maintain documented procedures to monitor and
measure on a regular basis the key characteristics of it’s operations and activities that
could have significant impact on the environment

Records to be kept of Monitoring procedures, results, equipment maintenance,

calibration etc.

4.5.2 Non-conformance and corrective and preventative action

Define responsibility for investigating and taking action on non compliance

4.5.3 Records

Procedures for identifying, maintaining and disposing of records such as audits and
training

4.5.4 EMS Audit

Audit to ensure compliance with ISO requirements, results to be provided to

management.

The aim of the audit is to assess whether the organisation's activities are in
compliance with any manuals, work instructions, etc. which form part of the EMS
and the organisations policy and objectives and targets. It's best to use someone with
knowledge of the place but not the person with direct management responsibility, to
obtain an independent view. You don't have to use a consultant.

4.6 Management Review

Organisation to review, (at intervals it decides), the EMS in the light of changing
policies, objectives etc.
Environmental Review

The preparatory review is included but is not part of the specification in ISO , (but is
very desirable) but is in EMAS

Initial Review
The review should include :-

An evaluation and recording of significant environmental effects

A review of legislation and regulations
A review of existing environmental controls and practices
Feed back from previous pollution incidents

Process to identify significant environmental aspects should include

Emissions to air
Releases to water
Waste management
Contamination of land
Impact on communities
Use of raw materials and resources
Other environmental issues

Include normal and unusual operating conditions

Use site visits, interview, checklists, measurements. Etc.

ISO was written with the intention that it should be comparable with EMAS,
however their are significant differences. Namely no public statement , no initial
review and no specified interval between audits.
EMAS Eco- Management and Audit Scheme

EMAS is a voluntary scheme to encourage businesses to go beyond mere compliance

with environmental legislation and produce an independently verified statement about
their performance.

They can then apply to have a particular site put on a European Register and display
the eco-audit logo. This may not be used on it's own without the statement that goes
with it and the statement of participation may not be used in product advertising or
on products or their packaging.

It is currently a voluntary scheme, although there are suggestions it may be

compulsory for some companies. At present, it applies only to sites used for
manufacturing, waste disposal, recycling, mining and power generation but, in the
UK, the scheme was extended to include local authorities, on an experimental basis.

The EMAS scheme was established by an EC Regulation in June 1993 but did not
come into force until '95. It was piloted in 1992 using 17 companies within 6 EC
countries. The UK government also investigated the application of the scheme in
local government and the scheme was piloted in seven local authorities. As a result a
guide was produced for local authorities and several LAs are registered now.

The site will be deleted if is fails to meet the deadline for the next validated
statement, fails to meet the requirement of the Regulation, ( by Regulation I mean the
complete law with it's preamble, articles and annexes) or breaches an environmental
regulatory requirement.

The EMAS registration is site specific. The Eco Audit regulation insists on a public
statement (not laid down in ISO) and insists on external verification. ISO does
include some verification but EMAS goes further and ensures you comply with the
public statement. The EMS of ISO is compatible with the requirements of EMAS.

Currently (2003) 3,695 sites are registered, (2400 of these in Germany).

It Allows voluntary participation by companies in the industrial sector in a
community Eco Management and Audit Scheme. The scheme originated within the
framework of the EC's 5th Action Programme on the environment and was revised in
2001.

The following criteria have to be met when applying for site registration:

a. An Environmental Policy

b. An Environmental Review (This isn't specified in ISO)

c. An Environmental Programme geared towards continuous improvement must be

set up.

d. Environmental Audits at least every 3 years

e. Objectives must be set up in the light of the results of the audit, and the
programme revised to include the achievement of the objectives.

f. The policy, programme, management system, review, audit procedures and

statement must be verified by an independent verifiers.

g. A site specific Environmental Statement must be drawn up. This is sent to the
competent body who then make this information available to the public.
Environmental Statement

The minimum content for the environmental statement is:-

Description of site activies

Assessment of all significant environmental issues relating to the activities

Summary of figures on pollution emissions, waste production, consumption of

raw materials, energy and water, noise and any other significant environmental
aspects

Other environmental performance factors

Presentation of the Policy and EMS

Deadline for next statement

Name of accredited verifier

Identification of significant changes since last statement

The information needed for registration includes

1. The name of the company

2. The name and location of the site
3. A description of the site processes and activities
4. The verified Environmental Statement
5. The name of the verifier
6. The deadline for submission of the next validated statement
7. A description of the EMS
8. A description of the Auditing programme established for the site.
BS8555

In 2003 A new British standard has been drafted to provide guidance to small and
medium enterprises to implement externally certified environmental management
systems. Based Acorn Trust's supply chain project, should help SMEs understand
legislation and reduce their impacts. Project Acorn, launched in May 2000 and
Government funded , aimed to encourage supply chain partnerships between SMEs
and larger firms, and develop formal management systems and indicators of
performance. The project relied on larger "mentor" companies such as Marks and
Spencers, Biffa, Rolls Royce, Cable and Wireless to introduce their suppliers to the
scheme.
The scheme offers a five-level step by step approach to implementing an
environmental management system compatible with the international standard
ISO14001, and a sixth level compatible with European standard EMAS.
The first three stages include identifying a firm's impacts, ensuring legal compliance,
and developing an improvement programme with targets and objectives.The step-
wise approach is an essential part of the scheme. Many SMEs are put off going for
certified systems by the apparent scale of the task. Acorn enables them to stop at any
stage while still gaining some credit.
To date, 21 SMEs have successfully achieved certification to ISO14001 through
Project Acorn, with a further 15 working towards it. Two of these intend to go for
EMAS. A further ten are at phase three.
For more info see http://www.theacorntrust.org/
It is anticipated that BS8555 will take a company 12-18 months to complete and it
only recognised in the UK although of course it can lead on to ISO14001 or EMAS.
It is also very detailed being 80 pages long compared to the 4 pages of ISO14001.

Pitfalls of implementing EMS

Exposes environmental liabilities (could be a benefit)

Uncontrolled environmental information (esp. EMAS)
Long term resource commitment
Cost of implementation and verification
Increasing some staffs work load