Overview

Increased general awareness and sense of responsibility to the environment are generating a need for companies to find ways of addressing environmental issues at a cost and learning curve that do not adversely impact on business. But why consider an Environmental Management System (EMS), and how does a business go about implementing one?

This article provides practical guidance and advice for those who have been tasked with implementing an EMS. It was originally written by Aneeta Patel, and updated and reviewed by Jenny Pulman, both Project Managers at Pro Enviro Ltd, an environmental management coinsultancy with many years of experience in helping companies implement EMS's whilst providing practical solutions to the problems faced.

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Why implement an EMS?

These days everyone accepts that we need to protect the environment from further damage caused by human activities; however taking positive action to address these issues is another matter entirely.

Environmental improvement is often driven by legislation, but typically this does not filter down to those who need to know about it the most – smaller companies. Ask many small companies to name a piece of environmental legislation that affects their business and they may be hard pushed to name even one. This is because many are busy focusing on what they need to do to fulfil orders, and may rely on their suppliers and contractors to inform them of applicable legislation as and when necessary, which means they never fully appreciate their environmental responsibilities and obligations.

Organisations that are more regulated (i.e. the more polluting industries) tend to be more aware of environmental issues, and in some cases the regulations have required these companies to go down the route of implementing an environmental management system.

However, for many companies the main driver for environmental improvement is supply chain pressure. Larger automotive and aerospace manufacturers have taken strides to improve their environmental performance and seen the benefits it brings. These companies have been driving their suppliers to do the same. For some suppliers improving environmental performance is now the only option for remaining on approved supplier lists.

Environmental management needs to become part of the day to day activity of a business in a way that health and safety management has become for the majority of companies. However, like health and safety this will take time.

In the meantime what can companies who want to - or need to - improve their environmental performance do? One of the most effective ways to manage a company’s operations, to minimise environmental risks and ensure they meet legislative requirements is through the implementation of an environmental management system (EMS) to recognised standards.

The two recognised standards for EMS are ‘ISO 14001’ and ‘EMAS’ (Eco-Management Audit Scheme). ISO 14001 is internationally recognised and has a higher take-up in the United Kingdom than the European Commission’s EMAS which requires companies to produce a publicly available verified environmental statement. Although, many organisations implement an EMS to retain existing business or win new contracts from larger customers, particularly in the automotive and aerospace sectors. However, there are other sound commercial reasons for implementing an EMS, such as costs savings and managing compliance with environmental legislation.

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Choosing your project team

Depending on the size of the company, the role of implementing and running an EMS is usually given to a middle manager. That person usually becomes known as the ‘Environmental Representative’. This may be one of several jobs the manager has within the company, but they should aim to spend around 1 day per week working on implementation and operation of the EMS. This time will be spent on administration, training, keeping abreast of regulatory changes, auditing, reviewing objectives and targets and devising procedures and work instructions. More time may need to be spent during the implementation phase.

Like any large, new project, it may be advisable to set up a project team to oversee the process of implementation. The environmental team(s) should include other managers and staff from various areas of the site.

The Environmental Representative and the environmental team(s) should have some degree of knowledge of environmental issues in relation to the company and have a working knowledge of the industry and processes on site and these must be well defined from the start.

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Benefits of an EMS

Why should your company implement an EMS?

A company with an EMS is demonstrating its commitment to minimising its impact on the environment. There are many other potential benefits:

• Creates awareness of environmental legislation applicable to your company so as to avoid any breaches and potential fines or prosecutions
• Cost savings from review of energy and raw material consumption
• Increasing employee motivation and enhanced personnel skills
• Increasing customer satisfaction and the opportunity to use certification as a marketing differentiator
• Potential to take advantage of future incentive schemes such as lower insurance premiums and improved access to finance which may come into operation
• Opportunity to integrate the EMS with other systems in operation on site to produce a streamlined approach to management

Some critics argue that implementing an EMS will not achieve significant cost savings. However, in our experience cost savings are largely dependent on the commitment of senior management and the resources made available to the environmental representative and team(s) to investigate and implement opportunities for process efficiency and waste minimisation.

For many companies, their limited resources are focused on the main objective – implementing an EMS and achieving certification to ISO 14001, and therefore the initial cost saving opportunities tend to be those ‘no cost’/’low cost measures’ that can be quickly and easily implemented. Other more significant opportunities can get overlooked or lost in the process. Whatever the reason, some of the more resource intensive, cost saving opportunities may just take longer to come to fruition. Therefore it is important that when companies implement an EMS, they put in place systems and procedures to capture, monitor, measure and manage those cost saving opportunities.

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ISO 14001 and EMAS explained

There are two formal approaches to implementing an EMS and these are ISO 14001 and EMAS.

ISO 14001 is a voluntary internationally recognised standard for EMS’s. The standard specifies the actual requirements for an EMS. It applies to those environmental aspects which the company can control and over which it can be expected to have an influence. This standard is now widely recognised as an effective element in helping sustain the environment for future generations and also helping ensure the long-term survival and prosperity of business through its three key aims of continual improvement, prevention of pollution and legal compliance.

EMAS, the Eco-Management and Audit Scheme, is a voluntary European Commission initiative. It aims to further recognise those companies that go beyond minimum legal compliance. EMAS has an additional requirement in that companies have to produce a formal and publicly available environmental statement which must be verified annually by an accredited verification body. The EMAS statement, gives interested parties detailed information about the company’s environmental performance, policy and objectives. However, the management system element of EMAS is based on ISO 14001. For those organisations that choose it, ISO 14001 can be a stepping stone for progression to EMAS.

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Guidance for your environmental review

An environmental review is the starting point for implementing an EMS. It will enable your company to have an overview and understanding of the environmental aspects and impacts of your company as required by ISO 14001. Reviews are also a good opportunity to find out about environmental legislation that may be applicable to your business and its activities, and to check if you need to do anything to comply.

When carrying out a review of your business, it is important to look at every process and area (internally and externally) with a view to identifying any emissions to air, discharges or releases to water and land, energy and resource consumption (raw and ancillary materials / products), waste, and issues that may concern or interest the local community.

The aim of the review is to collect enough information about the site in order to get an accurate picture of its environmental performance. This usually involves desk work, to review paper-based records, and a walk-round survey to see things in action. Records that should be collected and analysed in order to determine if there are any issues include:

• Previous environmental /energy survey reports
• Site plans and details of site history / development
• Planning restrictions (i.e. title deeds for the property / planning permission documents)
• Drainage plans and surveys
• Process information
• Maintenance plans and records
• Copies of any process authorisations, consents to discharge, licences, etc
• Waste records
• Water, air, or noise monitoring results
• Material usage data
• Material safety data sheets
• Energy and water bills
• Production records
• Any existing emergency and environmental procedures (e.g. fire, spillage, etc.)
• Records of any environmental incidents or complaints

Checklists are a useful aid during a site review because there can be a lot of information to gather and note down, such as:

• the condition of the site, buildings, storage facilities and any pollution control measures
• any visible evidence of land or water contamination
• how environmentally hazardous materials are managed
• how processes are controlled
• what type of waste is generated and how it is dealt with
• potential environmental risks and opportunities for improvement

Design and development functions are frequently overlooked during an environmental review. Many companies find that they can design out environmental impacts with only minor changes to products and processes.

A knowledge and understanding of environmental legislation is useful when undertaking an environmental review. By checking compliance, breaches of permit conditions or applicable legislation will become apparent from the review and will allow specific aspects to be targeted and priorities set.

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Evaluating your legal compliance

Compiling and maintaining a register of environmental legislation is not only a vital feature of an effective EMS, but will also ensure that your company is aware of current and proposed legislation and its compliance requirements.

Legal compliance is a minimum requirement for all responsible companies. A fundamental aspect of any EMS is the commitment to comply with legal requirements, so compliance to applicable legislation must be monitored and evaluated on an ongoing basis.

This can be achieved in various ways. Netregs is a free environmental guidance service that helps companies comply with environmental laws. Following registration legislation updates can be sent via email. There are also a number of publishing companies who offer subscriptions to legislation updates, such as Croner's (part of Wolter Kluwer) tel: 020 8547 3333. Some of the legislation in the updates may not be applicable to your operation however, so it is important to review the updates in detail in order to be fully aware of your legal duties. Trade associations and local business organisations also often offer such services.

Whichever legislative update service you use, the updates must still be reviewed by the environmental representative and assessed to determine if any requirements or changes are applicable to the company. The company’s own register should then be updated accordingly.

Pro Enviro has found that many companies find keeping up-to-date with environmental legislation an onerous and difficult task. Firstly, you need to be aware of legislation applicable to your business but then must review what changes or new legislation will affect you and identify what practical action is required by the company.

Legal compliance is often driven by the demands of consumer protection. Environmental legislation is enforced by bodies such as the Environment Agency or local authorities and the penalties for non-compliance can range from fines or criminal charges, to plant or line shut-downs.

It should be noted that a full and comprehensive legal compliance audit must be undertaken prior to a company seeking registration to an EMS standard, and that systems and procedures must be in place to monitor future legal compliance.

Auditing of any type, but particularly where there are serious legal implications, requires objectivity and understanding of all the issues. It is precisely for these reasons that many companies choose to rely on a consultant to undertake this task.

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Aspects and impacts

On completing the environmental review and legislation compliance audit you should have a good understanding of the aspects of the company that can have an effect upon the environment, and be able to make an assessment of the significance of these.

Environmental aspects and impacts can be defined simply as:

Environmental aspect:

any business activity that may have an impact on the environment such as emissions, noise, energy use….

Environmental impact:

the change that actually takes place in the environment because of the action of the aspects.Impacts might include toxicity due to an emission, natural depletion due to energy use, or nuisance or habitat disruption due to noise.

There are many tools available which can be used to evaluate the significance of your environmental impacts/effects and you should choose one which is appropriate to the nature and scale of the impacts/effects. Simple risk assessment methods are preferred by many companies and use a point scoring system to quantify significance. Those aspects with the highest scores should be used to set objectives and targets for improvement.

Aspects of the business that are affected by legal and other requirements should generally be treated as significant regardless of score.

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The importance of training and awareness

When implementing an EMS, it is important that employees at all levels are aware of their responsibilities. The more involved employees are and the more they understand why the company is implementing an EMS, the easier it will be to implement the system effectively.

Team briefings and the use of an environmental notice board are good methods of communicating that can be used to convey the benefits of environmental management and make employees feel they are participating in the company strategy.

Employees can be trained in various methods depending on their role within the system. Operators will need to know the practical procedures on site, such as how to deal with spillages and where to dispose of waste. Design engineers will need to be aware of alternative materials and production processes. The environmental representative will need to be aware of the management side of the EMS and will need a comprehensive knowledge of the company’s environmental impacts. The environmental team(s) may need to know about energy efficiency and waste minimisation in order to be able to identify opportunities for environmental improvement and cost savings. Senior management will need an overview of the costs and benefits of environmental management.

The environmental representative can spend time training employees, or your consultant or environmental training organisation can assist in holding briefings and presentations throughout the company.

Those personnel chosen to be internal environmental auditors need to be trained specifically in auditing an EMS. It cannot be presumed for example that a quality manager will automatically be able to audit an EMS even though he/she is familiar with the audit process. It is wise to shop around when seeking auditor training – be aware of the credibility of the training provider, and capability of the person who will be training your team.

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Practical advice

A fundamental part of any management system is documented operating procedures and instructions; however there are also practical measures which need to be implemented before seeking certification. This includes measures to deal with any immediate environmental risks and potential non-compliances with legislation, such as building bunded areas for the storage of hazardous materials and wastes, placing spillage kits around the site, and identifying what types of drains there are.

In addition to the more immediate measures described above, other measures which can lead to potential cost savings for the company should also be identified. These should be linked to the significant aspects identified by the company. For example, if energy consumption is identified as a significant aspect - which it will be for most companies - then the company should investigate how it can be more energy efficient and set itself measurable objectives and targets to achieve reduction in usage.

Companies trying to find practical advice on reducing their environmental impacts often benefit from the experiences of other companies within the same industry. The idea of networking amongst companies with similar operations and the same goals can provide numerous benefits when implementing an EMS.

For further information on networking contact your trade association, local Business Link, the Government’s Envirowise and Action Energy schemes. In addition, Pro Enviro, run a number of ISO 14001 networks.

It is important to remember that the implementation of an EMS is not the final step in environmental management - it is only the beginning. Continually improving your company’s environmental performance is the goal.

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Seeking certification

Implementing an EMS is a one thing, but certification of your EMS is another. Organisations who implement an EMS due to supply chain pressure, seek certification because they need to demonstrate to their supplier that their EMS meets the requirements of ISO 14001. This is one reason why companies seek certification. Other reasons include:

• regular external assessments provide a good incentive to maintain the EMS and to keep making improvements to environmental performance
• it improves relationships with environmental regulators and other stakeholders
• certification has led to new customers and/or increased market share

Some companies find that assessors can be helpful in identifying further environmental improvements. However good your organisation might be, there are always opportunities for improvement, and external assessors can be useful because they can identify areas for improvement which may be easily overlooked by those inside the organisation.

Selecting the right certification body is important, which shouldn’t just come down to cost. As a minimum, the certification body should be accredited by UKAS (United Kingdom Accreditation Service). This means that the certification body has been assessed by a national accreditation body recognised by the government for its competency to undertake ISO 14001 external audits.

Other important aspects include whether they have auditors who have experience of your industry, and whether these auditors can perform joint audits, for e.g. quality and environmental, in order that you can save time and money.

And finally, what other benefits do they offer? Easy to access advice and support, regular environmental updates and news to keep you abreast of environmental issues and a full range of environmental training events are all useful service elements.

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Notes on integrating your management system

Many companies now have multiple management systems in place, such as quality and safety management systems, or quality and environmental systems, or even all three. This places a high administrative burden on staff and is time consuming, as well as reducing the time available to achieve business goals.

Many companies are now choosing to integrate their management systems to make running separate systems less time consuming, disruptive and expensive. Pro Enviro has been helping companies integrate systems for a number of years. If your company already has management systems in place, it may be beneficial to integrate your EMS into these. However, integration does require a significant amount of planning and you should be fully aware of the requirements of each standard before going down this road.

Jenny Pulman
Pro Enviro Ltd.
www.proenviro.com/UK/

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