WRAP Your Guide to Environmental Management Systems

8/13/2019 WRAP Your Guide to Environmental Management Systems

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Your Guide to Environmental

Management Systems

Business Resource Efficiency Guide

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Our vision is a world withoutwaste, where resources are

used sustainably.We work with businesses andindividuals to help them reap thebenefits of reducing waste, developsustainable products and use

resources in an efficient way.Find out more from the WRAPResource Efficiency Helpline on0808 100 2040 or at www.wrap.org.uk

1 Introduction to environmental management 2systems (EMS)

2 Commitment 6

3 Organisation and personnel 8

4 Initial review 11

5 Environmental policy 13

6 Significance of environmental aspects 18

7 Register of Legislation 22

8 Objectives and targets 23

9 Management programme and Management 25Manual

10 Audits and reviews 29

11 Training and awareness raising 33

12 ISO 14001, EMAS and BS 8555 35

13 Further information 41

Appendix 43

Contents

eSection 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Section 9 Section 10 Section 11 Section 12 Section 13 Appendix
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Your Guide to Environmental Management SystemsWRAP 1

Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Section 9 Section 10 Section 11 Section 12 Section 13 Appendix

Summary

More and more, stakeholders and customersare expecting organisations to demonstratetheir commitment to managing theirimpacts on the environment. This might beinsurers or financiers wanting to understandhow environmental risk is managed in anorganisation, or customers wanting to knowthat suppliers in their supply chain are takingtheir own environmental responsibilitiesseriously. Having an environmental

management system (EMS) is one wayfor an organisation to demonstrate that itaddresses and minimises its environmentalimpacts, manages its legal compliance andcontinuously improves its environmentalperformance.

This guide contains a practical guide todeveloping an EMS. It is envisaged that themajority of users will work through the guide,section by section, using it to support themduring the development of systems andprocesses necessary for their own EMS. So,whether you are just looking to develop anenvironmental policy or a full-blown EMS, thisguide is for you. It will provide you with theadvice and sources of support you will need tohelp you along the way.

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e Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Section 9 Section 10 Section 11 Section 12 Section 13 Appendix

1 Introduction to environmentalmanagement systems (EMS)

1.1 What is an EMS?

Increasingly, organisations are recognisingthat the environment is a management issueand not just a matter of compliance. An EMSis a systematic approach to managing yourorganisations impacts on the environment.Having and following an EMS is voluntary, butorganisations with an EMS have an explicitcommitment to continual environmentalimprovement.

Setting up an EMS will provide yourorganisation with a framework throughwhich its environmental performance can becontrolled and improved.

An EMS:

is a mechanism for defining environmentalresponsibilities for all staff, helping themto understand the environmental impact oftheir activities and individual actions;

ensures that all operations have

procedures that minimise their impacts;

records environmental performanceagainst set targets;

can be audited; and

will help you identify opportunities toreduce waste and thus reduce youroperating costs.

To implement an effective EMS, you needto know your business and understand itsimpacts on the environment. By knowing

how your business operates, you will be ableto easily identify how to improve efficiency,reduce costs and improve profits.

Although many organisations have alreadymade significant improvements in theirenvironmental performance, an EMS willensure that improvements continue throughongoing maintenance and monitoring ofthe system. An EMS also ensures thatenvironmental performance and other relatedissues are raised regularly with seniormanagement, and that the momentum formaking improvements is maintained.

1.2 Potential benefits of implementingan EMS

Financial

Identification of opportunities to reduce-waste and thus reduce raw material,utility and waste disposal costs.

Increased profits.-

Reduced risk of fines for non-compliance-with environmental legislation.

Lower insurance premiums as risks and-liabilities are reduced.

Retaining site asset value.-

More easily obtainable bank loans.-

Attracting shareholders and investors.-

Productivity

Improved process control (i.e. fewer-rejects, less rework, higher yields).

Reduced use of raw materials and-consumables.

Less waste.-

Sales and marketing

Improved products.-

Competitive advantage (i.e. preferred-supplier status).

Increased sales achieved through-promotion of greener credentials.

Management

Structured approach to environmental-issues and continual improvement.

Keeping ahead of environmental-legislation.

Better relations with regulators.-

Public relations

Improved relations with local community-and environmental groups.

Improved public image.-

To implement aneffective EMS,you need to knowyour businessand understandits impacts on theenvironment. Byknowing how yourbusiness operates,you will be able to

easily identify howto improve efficiency,reduce costs andimprove profits.

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Personnel and training

Improved working environment.-

Reduced potential for environmental-

incidents.Increased employee motivation and-environmental awareness.

Peace of mind

Conforming to legal requirements.-

Avoiding penalties for pollution.-

Avoiding bad publicity from pollution-incidents.

1.3 What does an EMS involve?

An effective EMS includes:

an assessment of how your organisationsactivities, products, processes and servicesmight affect the environment;

the development of an environmentalpolicy;

an environmental improvementprogramme;

defined roles and responsibilities for allemployees;

a training and awareness programme;

written procedures to control activities with

a significant environmental impact;

a controlled system of records;

periodic auditing to ensure effectiveoperation; and

a formal review by senior management.

The various elements of an EMS are shown inFigure 1.

Remember the three Cs

Commitment - gain support for the EMS at

all levels within the organisation throughgood communications.

Continuity - ensure the system remainsrunning once it has been established.

Continual improvement - continuouslyreduce the organisations significantenvironmental aspects.

Objectives and targets

Organisationand personnel

Training andawareness raising

ManagementProgramme

ManagementManual

Evaluation of significantenvironmental aspects

Register ofEnvironmental Aspects

Register of Legislation

Commitment

Initial review

Policy

Reviews

Audits

Records

Operational control

Figure 1: Elements of a typical EMS

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1.4 Types of EMS

There are three strategies available toorganisations wishing to implement aformal EMS:

develop their own in-house EMS;

follow the guidelines of the internationalstandard ISO 14001, the EU Eco-Management and Audit Scheme (EMAS)1or the British Standard BS 8555 (designedspecifically for small and medium sizedorganisations), but do not pursue formalISO 4001 certification or EMAS registration;and

pursue formal ISO 14001 certification orEMAS registration.

All three strategies are voluntary, but differ intheir scope and approach. The choice dependson what is right for your organisation. TheWRAP Resource Efficiency Helpline (0808 1002040) may be able to help you decide what isbest for your circumstances.

1.4.1 The advantages of a formal approach

A formal approach not only increases thecommitment for environmental improvementacross the organisation, but also identifies

opportunities for improvements and costsavings on an ongoing basis. AchievingISO 14001 certification or EMAS registrationmay increase the credibility of your EMSwith customers and suppliers, as they areinternationally recognised standards.BS 8555 is a British Standard (published inApril 2003), but has particular merits forsmaller organisations.

Many organisations have found that, afterimplementing a formal EMS, the cost savingrealised has significantly outweighed theexpenditure in achieving it. The disadvantagesof adopting a formal standard often stem fromthe introduction of unnecessary bureaucracy.

An EMS contains several features presentin a quality management system (QMS) andthere may be advantages to integrating thetwo systems. There are differences betweenan EMS and a QMS, but they are bothfundamentally concerned with ensuring thatspecific management objectives are met.

There is a growing international consensusthat these standards should align as closelyas possible, thus helping organisationsdevelop integrated management systems.

However, it is not appropriate to simplycombine EMS and QMS elements. Instead,the emphasis should be on integratingenvironmental issues into the existingmanagement structure of an organisation.

BS 8555

The phased EMS implementation approachused by BS 85552and piloted through theInstitute of Environmental ManagementAssessment (IEMA) Acorn Schemebreaksdown the process of installing a formal

EMS into five Phases. A sixth Phase allowsorganisations to develop systems, with thepossibility of seeking ISO 14001 certificationor EMAS registration.

BS 8555 also incorporates ISO 14031:2000that gives guidance on the design and use ofenvironmental performance evaluation.

Phase 1 Commitment and establishinga baseline

Phase 2 Identifying and ensuring compliance

with legal and other requirementsPhase 3 Developing objectives, targets and

programmes

Phase 4 Implementation and operation ofthe EMS

Phase 5 Checking, auditing and review

The introduction of BS 8555 allowsorganisations that do not possess theresources to implement ISO 14001 orEMAS, but which have made progress inenvironmental management, to receiveacknowledgement of their efforts.

An independent inspection scheme has beendeveloped by the Institution of EnvironmentalManagement and Assessment (IEMA) whichoffers accredited recognition for organisationsevaluating and improving their environmentalperformance through the phasedimplementation of an EMS. Full details of theAcorn Inspection Scheme are given on IEMAswebsite (www.iema.net/acorn).

1 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:342:0001:0045:en:PDFRegulation (EC) No 1221/2009.2 Full title: Guide to the phased implementation of an environmental management system including the use of environmental

performance evaluation.

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http://www.iema.net/ems/acorn_schemehttp://www.iema.net/acornhttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:342:0001:0045:en:PDFhttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:342:0001:0045:en:PDFhttp://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:342:0001:0045:en:PDFhttp://www.iema.net/acornhttp://www.iema.net/ems/acorn_scheme


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For simplicity this document refers only to ISO14001 and EMAS. For more information aboutBS 8555 and free advice about its potentialbenefits for your organisation, please contact

the WRAP Resource Efficiency Helpline on0808 100 2040.

1.5 EMS terminology

As well as the familiar term environmentalimpact, published guidance on formal EMSsuses the terms environmental aspect asdefined below.

Environmental aspect. Any elementof a organisations activities, productsor services that can interact with

the environment. This can meanalmost anything an organisation doesfrom industrial processing to officeadministration.

Environmental impact. Any change to theenvironment wholly or partially resultingfrom an organisations activities, products,processes or services either directly orindirectly. An impact can be adverse orbeneficial. An environmental aspect willhave a corresponding environmentalimpact (or even several impacts).

Do not confuse an environmental audit withan environmental review.

Initial environmental reviewkick startsthe EMS.

Internal environmental auditsmaintainits momentum.

The management review allows seniormanagement to consider how well theEMS is working.

EMAS A full list of definitions is provided inArticle 2 of the Regulation

ISO 14001 Terms and definitions are detailedin Clause 3 of the Standard

1.5.1 United Kingdom Accreditation Service3

The United Kingdom Accreditation Service(UKAS) is the sole national accreditationbody recognised by Government to assess,against internationally agreed standards,organisations that provide certification,testing, inspection and calibration services.

Accreditation by UKAS demonstrates thecompetence, impartiality and performancecapability of these organisations.

UKAS maintains a list of UK accreditedenvironmental evaluators.

3 www.ukas.com

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2 Commitment

2.1 Overcoming obstacles

Many organisations experience someexpression of negativity about the intentionto implement an EMS. This can comefrom management, employees or otherinterested parties such as shareholders. Suchconcerns can jeopardise an EMS even beforeimplementation has begun. Some of thecommon misconceptions surrounding an EMSare discussed below:

We dont know what an EMS is. It isimportant to explain the basic aims andbenefits of an EMS to all interested partiesearly on in the process perhaps bygiving a presentation to the managementboard or by placing the information ona notice board, or by featuring it on theorganisations intranet or in a newsletter.

We dont have any environmental issues. Any organisation that buys raw materials,uses energy and water, receives and makes

deliveries, uses packaging or producesliquid/solid waste has an impact on theenvironment.

We dont have the time or the resourcesto implement an EMS.This is a commonconcern and one to which there is nosingle, straightforward answer. However,an EMS will help your organisation tobecome more efficient by reducing wastegeneration and the consumption of rawmaterials and utilities. The time andresources needed to implement an EMS

should be viewed as an investment thatwill produce high yields in terms of costsavings and thus make the organisationmore profitable. Increasing numbers oforganisations have already invested in anEMS and are reaping the benefits.

Does an EMS have to be implementedacross the whole organisation?An EMSdoes not have to be implemented acrossthe whole organisation. It can be piloted orimplemented in one part and then rolledout to other sites/facilities or operationalareas as and when required.

No one in the organisation is trainedto implement an EMS.One or twomembers of staff will need to have anin-depth knowledge of the EMS. However,most employees just require an overallunderstanding of the environmentalissues relating to the job they do. Byusing the guidance in this document orfollowing the requirements of a recognisedstandard such as ISO 14001, it is possible

to implement an EMS without the need foradditional expert or third-party training.Whether carried out by external partiesor undertaken in-house, training can berelatively inexpensive and can be scheduledto avoid any operational disruptions. This isparticularly true where a train the trainerapproach is applied (i.e. a person or smallgroup is trained to then carry out furthertraining within the organisation).

Will it cost money? Almost invariably,the implementation of an EMS entails

some costs. These vary considerably anddepend upon the size of the organisation,the number of sites involved, the numberof employees and the level of existingin-house expertise. If costs are a majorconcern, then carrying out a simple cost-benefit analysis will help to estimatepotential savings. A walk around your sitewill probably highlight a number of no-costor low-cost opportunities that will producesignificant cost savings and thus offset theinitial cost of implementing the EMS.

2.2 The importance of top-level commitmentAlthough an EMS needs to be adopted at alllevels in an organisation, its effectiveness willdepend on the level of commitment from themanaging director and other senior staff.

Therefore, before starting to design thesystem, it is essential to obtain the fullcommitment of senior management to theaims and objectives of your EMS.

The time andresources needed toimplement your EMSshould be viewedas an investmentthat will producehigh yields in termsof cost savingsand thus make theorganisation more

profitable.

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The benefits that senior managementcommitment gives an EMS include:

importance within the organisation;

a consistent approach throughout theorganisation (i.e. setting an example fromthe top);

gaining the commitment of other keymembers of the organisation; and

authorisation to use other availableresource (i.e. staff time and budget).

One of the easiest ways of securingcommitment is by estimating the potential

cost savings from adopting an EMS. Forexample, calculate the annual costs of water,gas, electricity and waste disposal for yourorganisation by looking at the bills from the

previous 12 months. As a general rule, itshould be possible to cut the costs of theseservices by at least 10% to 15% withoutsubstantial capital expenditure.

The commitment of senior managementis important in obtaining sufficient time,resources and money to achieve continualenvironmental improvement through an EMS.

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3 Organisation and personnel

3.1 Responsibility for implementation

Sharing responsibility for the implementationof an EMS across all levels will enable theorganisation to get the most out of it. Manyorganisations have difficulty deciding whoshould be responsible for implementing theirEMS. Some will be in a position to appoint anenvironmental manager and some will not.If you fall into the latter category, you needto allocate the time to someone with similar

work responsibilities and skills.The person responsible for implementingan EMS is described in ISO 14001 as theManagement Representative. This documentalso uses this term.

3.1.1 The Management Representative

The Management Representative isresponsible for:

undertaking the initial review;

implementing and maintaining the EMS;

gathering, organising and disseminatinginformation;

co-ordinating inputs from other people withcomplementary responsibilities;

reporting environmental performance tosenior management;

delegating tasks and establishingdeadlines; and

producing, maintaining and controlling theEMS Manual or Management Manual.

The Management Representatives key

functions are:

communication;

co-ordination;

motivation; and

training/raising awareness of allemployees.

The Management Representative shouldpossess the following qualities:

some experience of environmental, health

and safety issues; andreasonable knowledge of the processescarried out at your site(s).

3.2 Seeking help from other people

Many organisations have found that it hastaken some time to implement their EMSbecause the person responsible has otherroles with an equal call on their time.

The Management Representative should seekhelp from the:

site/process engineer much of an

EMS revolves around greater efficiencyfrom process operations and monitoring.Therefore, it is logical for the personwith responsibility for monitoring andmaintaining process equipment to beclosely involved in the development andmaintenance of your EMS;

health and safety manager much of theinformation required under health andsafety legislation is applicable to an EMS.Given these close links, the health andsafety manager should also be asked tohelp develop your EMS;

quality assurance manager if yourorganisation has a quality assurancesystem, the documentation procedure islikely to relate to EMS requirements. Thedepartment/individual responsible forquality assurance in your organisationshould, therefore, be able to help developprocedures and documentation; and

purchasing manager in addition toproviding information about your rawmaterial and utility costs, the purchasing

manager will need to be involved if liaisonwith suppliers is required.

TIP: During the development of your EMS, itmay be worth employing a student on workexperience or a graduate placement to providetemporary assistance in gathering data.

Many organisationshave difficultydeciding who shouldbe responsible forimplementing theirEMS.

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3.3 Environmental management team

Setting up an environmental managementteam will help you implement and operateyour EMS effectively. Depending on the size

and nature of your organisation, this teamcan be the entire workforce (organisationswith up to 10 employees) or a core group ofpeople representing different departmentsor operational areas together with a memberof senior management (to provide top-levelcommitment). Everyone with primaryresponsibilities within the EMS should bea member of the team.

Although individual members and theirlevel of involvement will depend on theorganisation, team members can include the:

managing director;

environmental manager or ManagementRepresentative;

works director;

quality manager;

maintenance engineer(s);

shift foremen;

works engineer; and

human resources/training manager.

The environmental management team has avital role in planning the implementation ofthe EMS and further embedding the processinto general work practice. The specific roleof the team should be to:

attend regular team meetings that followan agenda and are minuted thesedocuments will provide records for themanagement review process;

assist with the implementation of the EMS;

encourage other staff to be involved; and

draw up action plans to ensure thatimprovements are made and that progressis monitored.

Each member of the team should have clearlydefined responsibilities. It is also importantthat specific tasks are assigned to individuals(e.g. workshop manager, section head andenvironmental manager).

TIP: You may find it helpful to set up smallerproject teams or working groups, whichshould be asked to report back to theenvironmental management team.

3.4 Communication

Commitment to a project at the proposalstage can soon wane, or even be withdrawn,if things do not go to plan or circumstances

or individuals change. It is important to keepmanagement and staff informed. All too oftennew schemes start off with good intentions,but enthusiasm can flag if people are not keptup to date with what is happening. Effectivecommunication can ensure engagementand assist to embed principles into workingpractices.

Communication cannot be overemphasised.The more employees are involved in theEMS, the more committed they will be andthe easier it will be to implement the system

effectively. An edict from senior managementon its own will only achieve short-termsuccess. To ensure continual improvementand long-term success, training andcommunication are essential.

Before beginning your environmentalreview, let employees know what ishappening and encourage them to startthinking about the part they can play.

Communicate with employees (e.g. usingan environmental notice board, internal

memos, meetings, intranet, team briefingsand letters).

Ask employees for their ideas. Normally,those doing a job every day will haveideas about how things can be done moreeffectively. Ensure that these ideas areacknowledged and are not ignored.

Be open, let employees know that somedecisions are not set in stone.

Provide feedback both good and bad.

Make sure employees understand andbelieve in any procedures introduced aspart of the EMS through suitable training.

Set up short, but frequent, environmentalmanagement team meetings and makesure line managers are brought into theprocess.

REMEMBER: Everyone gains, professionallyand personally, through effectivecommunication. These skills should beembedded within your organisation. Itrequires a commitment, but the return on the

investment is well worth the time and energy.

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3.5 Resources needed

Before implementing your EMS, it isimportant to consider what will be neededin terms of time and other resources.

The time taken to implement an EMS is typicallybetween 12 and 18 months, though there is nostandard timescale; it will depend on:

the organisation;

site circumstances;

the experience of the personnel involved;and

the type of EMS chosen.

TIP: Delegation and team working can help toreduce the time taken significantly.

Tasks include:

administrating the system;

monitoring goals and targets;

helping to produce and revise workprocedures;

arranging for training for new employees;

adapting the system to accommodate

changes in regulatory controls andmanufacturing processes; and

liaising with external consultants.

Auditing the system and ensuring that anycorrective actions are carried out will takehalf a day a week. The internal auditor(s)should be allowed between 3 and 4 hours aweek to carry out one or two audits.

While this may seem a lot of staff time,remember that 20% of the salary of a senioremployee is often less than the anticipated

cost benefits (i.e. between 10% and 15% ofthe combined cost of utility consumption andwaste disposal). In addition, do not assumeyou are starting from scratch it may bepossible to build on existing procedures.

Senior management should allocatesufficient time for regular managementreview meetings and for considering requestsfrom the Management Representative forimprovement measures involving capitalexpenditure. If your organisation has a QMS,the management review can be linked to

similar procedures.

3.6 Using an external consultant

Asking an external consultant to helpmay reduce significantly the time spenton implementing your EMS. Although this

will cost money, it may save you time andallow you to benefit from the consultantsexperience. However, it is essential youprovide the consultant with a clear brief aspart of the written contractual agreement.

There may be cases where you need toget specialist advice and assistance,particularly in the areas of legal compliance,environmental aspects and impacts,emergency planning and environmentalauditing.

When seeking outside help, check thatpotential consultants have the necessaryexperience and qualifications. Choose anenvironmental specialist who is familiar withthe particular issues associated with yoursector and who understands staff needs.A consultant specialising in the qualitystandard ISO 9000, who doesnt havesignificant EMS experience, is unlikely tohave sufficient expertise.

TIP: A consultant does not negate the need

for an on-site Management Representative;an organisation must take ownership of theEMS to ensure continuous improvement.

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4 Initial review

4.1 Introduction

Once you have assessed the resourcesneeded, gained commitment and startedraising awareness for the EMS, you can startcarrying out an initial review. There are fourkey areas that this review should cover.

Identifying environmental aspects of youractivities and their impacts associated withnormal operating conditions, abnormal

conditions (such as start-up and shut-down) and emergency situations.

Assessing relevant legislation.

Reviewing existing environmentalmanagement practices and procedures.

Evaluating previous emergency situationsand accidents.

It will also enable you to:

prepare/revise your environmental policy;

identify opportunities to improveperformance (e.g. improve processefficiency, and reduce waste generation,water use and energy consumption); and

set objectives and targets for improvement.

4.2 The purpose of the initial review

During the implementation of an EMS, theinitial review is the first step in which anorganisation begins to consider systematicallyall the factors driving the complexrelationships it has with the environment.The initial review will give you the opportunityto take a snapshot of your organisationsattitude to environmental issues and its actualperformance, problems and opportunities. Inparticular, the initial review is designed to:

identify the ways in which site operationshave an impact on the environment;

establish which of these impacts aresignificant and in need of improvement;

identify breaches or potential breaches oflegislation;

identify relevant EMS documentation whichneeds to be put in place;

start to quantify emissions, discharges andmaterial/utility use; and

identify and prioritise opportunities toimprove performance and reduce wastearisings.

A comprehensive environmental review willhelp you to implement either an informal or a

formal EMS. The output of the review shouldenable you to:

start making policy commitments or checkprogress against your current policy; or

draw up and implement an action plan todeal with the issues arising.

REMEMBER: Whether you have an EMS ornot, you must comply with UK environmentallegislation and be able to demonstratecompliance to the appropriate regulatoryauthorities.

4.3 Gathering data

The main tasks involved in an initial revieware data gathering and analysis.

Worksheets 1 and 2 (see Appendix) will helpyou with these tasks:

Worksheet 1 :Documents needed for aninitial review; and

Worksheet 2

:Initial review.

The first worksheet identifies the documentsneeded to determine your organisationsenvironmental aspects and impacts. Note thatyour organisation may not have, or even need,all this information it will depend on yourcircumstances.

This worksheet should be used by theManagement Representative as a checklistwhen gathering data for the review. For thereview to be effective, all documents should

be made available and filed (with copies) forfuture reference.

The initial reviewwill give you theopportunity to takea snapshot ofyour organisationsattitude toenvironmentalissues and its actualperformance,problems and

opportunities.

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The second worksheet, which is divided intosix sections, can be used by the ManagementRepresentative to collect the informationneeded for an initial review of the site. The six

sections cover:

site issues;

utilities;

inventory of raw materials;

aqueous effluents;

solid wastes; and

emissions to atmosphere.

Some sections may not be relevant to yourorganisation or you may need to expand the

worksheet to cover other areas of interestsuch as:

the sites history;

the site setting and natural environment;

management structure andresponsibilities;

management systems;

site operations;

general health and safety issues;

materials storage and handling; and

noise and vibration.

TIP: To ensure that the figures entered in thisform are comprehensive and accurate, theManagement Representative should carry

out a site survey rather than relying solely onpaper records. You may need to interview therelevant operators and managers to obtainsome of the information.

The information gathered by the ManagementRepresentative can also be used to:

review existing practices and procedures todetermine if improvements are needed;

review past incidents and take action toimprove performance; and

identify breaches or the risk of breaches of legislative requirements and reviewmanagement control.

Once the review has been undertaken, yourorganisation is in a better position to:

prepare/revise your organisationsenvironmental policy;

compile a Register of EnvironmentalAspects and identify relevant environmentallegislation;

identify opportunities to save money byreducing waste; and

set site-specific objectives and targets forimprovement.

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5 Environmental policy

5.1 Introduction

An environmental policy is a writtenstatement outlining your organisationsmission in relation to managing theenvironmental impacts of its operations.The policy is the driving force behindthe objectives, targets and managementprogramme of your EMS. The policy:

states the organisations aims and

objectives and forms the basis for its EMS;is endorsed and actively supported bysenior management and accepted by allstaff;

allows management to communicate itsaims and objectives to employees and otherinterested parties, including shareholders,customers and suppliers; and

should be part of the business strategy.

In the case of a multi-site operation, theremay be a number of group or divisional

operating statements which, whencombined, represent the view of the holdingorganisation.

Writing an environmental policy is a voluntaryundertaking in the UK, and the structureand content are not regulated under UKlegislation. For organisations intendingto implement a formal EMS includingISO 14001 and EMAS, the environmentalpolicy is a mandatory document providing acornerstone in the systems development andimplementation.

The written policy needs to:

be specific to your organisation and itsenvironmental impacts; and

only address issues relevant to yourbusiness activities.

For organisations intending to obtaincertification to ISO 14001 or registrationto EMAS, the environmental policy is thecornerstone of the EMSs development andimplementation. Both give guidance on theprinciples on which the environmental policyshould be based. ISO 14001 and EMAS specifythat the environmental policy must includecommitments to legislative compliance andcontinual improvement.

The order followed by ISO 14001 placeswriting a policy before identifying significantaspects and legislation. However, manyorganisations complete these stages beforefinalising the environmental policy. Thisensures that the policy is appropriate for anorganisations activities.

5.2 Communication and review

The environmental policy should be:

communicated to all staff, contractors andsuppliers4;

made available to customers,shareholders, other stakeholders and thepublic4;

located in a prominent place on site, suchas the reception area; and

reviewed regularly and, if necessary,revised to take account of developments inyour EMS and significant changes to yourbusiness activities or operations.

TIP: Start by reviewing the policy after thefirst six months of operation of the EMS andthen annually.

GOOD PRACTICE:Even if your organisationis not intending to adopt a formal EMS, it isworthwhile designing your policy carefullyas you will wish to publicise it and yourcustomers will want to see it.

The policy is thedriving force behindthe objectives,targets andmanagementprogrammeof your EMS.

4 Key requirement of ISO 14001 and EMAS

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5.3 Content and style

There is no standard format for writing anenvironmental policy, but the style shouldreflect your organisations culture.

TIP: If your organisation is closely linked tokey customers through the supply chain, agood starting point is to obtain a copy of theirenvironmental policies and ensure that yourpolicy reflects their requirements and needs.

Look at examples of policies written by otherorganisations and select the format and style

most appropriate to your own.

Consider the following:

make the environmental policy realistic andpractical for your organisation comparewhat you actually do with what the policysays you will do;

keep the policy short if it is longer than anA4 sheet, then it is probably too long;

the policy is meant for everyone to see, somake sure it is easy to read and understand;

the policy must be realistic, achievable andrelevant to your organisations activitiesand practices;

to demonstrate commitment to making thepolicy work, get the policy signed, dated andendorsed by the managing director, chiefexecutive or another senior manager; and

state the review period.

The targets and timescales stated should berealistic and address overall environmentalperformance. The policy should be influenced

by the findings of the environmental review andshould be finalised after this has taken place.

An environmental policy may encompass thefollowing:

liaison with the local community and howany complaints received will be addressed;

compliance with the requirements ofenvironmental legislation and approvedcodes of practice;

assessment of environmental impact ofpast, current and future operations and setobjectives/targets to reduce these impacts;

continually seeking to improveenvironmental performance;

environmental considerations and criteriain capital investment decisions;

fostering the commitment of all employeesto improve the environmental performanceof the organisation;

use of sustainability principles for all rawmaterials, supplies and energy efficiency,where achievable;

aiming to prevent all types of wastegeneration and to increase the reuse andrecycling of waste, and recovery of othervalue (e.g. energy) from waste;

reporting publicly on environmentalobjectives and targets; and

expecting similar environmental standardsfrom all third parties (i.e. suppliers,vendors and contractors).

An example of an environmental policy isgiven in Figure 2.

You may also find Table 1, the Policy WritingChecklist, useful.

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Company X

ENVIRONMENTAL POLICY

Company X is a young firm of environmental consultants,specialising in environmental business support solutionsto ensure regulatory and legal compliance. We employ over450 staff and operate from two sites. Company X providescost-effective management support for environmentalmanagement.

Company X ensures that all activities carried out by theorganisation comply with all relevant environmentallegislation.

The organisation is committed to the prevention of pollution;we aim to continuously improve our environmentalperformance through the support and involvement of allemployees and any other interested parties. In recognition ofthis, we have implemented an environmental managementsystem.

We aim to:

actively reduce waste through our resource efficiencypolicy, which describes our principle of preventing, reusingand recycling all our office waste;

maximise efficient use of natural resources through office

best practice guidelines;continue to operate a purchasing policy to ensure as muchmaterial as possible is sourced from recycled material;

reduce the amount of energy consumed during officehours by efficiently using equipment and operating ourswitch off when not in use policy;

continue to encourage our clients, suppliers andstakeholders to adopt our environmental principles anddevelop an environmental management system in theirown organisations; and

review our EMS including this policy and publish anEnvironmental Statement annually.

Signed: Bea Green April 2012

Company Director Issue 1

The policy should contain a

commitment to legislation

compliance

The policy should contain

a long-term commitment

to pollution prevention and

contain a commitment to

continuous environmental

improvement

This section should contain

some broad aims that are

related to the organisations

identified environmentalimpacts (e.g. waste, energy,

water, raw materials)

The policy should be signed bythe most senior manager and

be reviewed on a yearly basis

and made available to the

public and other stakeholders.

Figure 2: Example environmental policy

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Table 1: Policy writing checklist

Issue Comments

Purpose Why are you creating anenvironmental policy?

Scope Does it cover business unit/division/entire organisation?

Does it give a brief description oforganisations activities?

Does the policy reflect theorganisations values and principles?

Objectives Have you identified about five keyenvironmental objectives?

Are these directly relevant to yourorganisation?

How were these identified?

Are they achievable?

Do they reflect your significantenvironmental impacts?

Legalrequirements

Do you intend to meet/exceed legaland other requirements?

Responsibilities Who is responsible for overseeingand implementing the policy?

Communication How will the policy be communicated

to employees?

How will it be communicated tocustomers, suppliers, contractorsand other interested parties?

Review Is this document to be reviewedannually/periodically?

By whom and under whatcircumstances?

Authorisation Who is responsible for authorisingthe policy?

Is evidence included?

Is it dated and subject to versioncontrol?

ISO 14001requirements

Have you included a commitmentto prevent pollution?

Have you included a commitmentto continual improvement?

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5.4 Implementing the environmental policy

Developing and writing the policy are just thefirst steps. The environmental policy mustthen be put into practice. The environmental

policy needs to be a living document that isimplemented during day-to-day activities.

Once the policy has been completed it mustthen be communicated to others.

5.4.1 Internal communication

Make sure that all employees know aboutyour environmental policy. Check thatemployees have received and understoodthis information. Below are some examplesof what you can do to actively promote your

environmental policy to all employees.

Present the policy at a meeting for allemployees.

Post the policy on the office walls, thereception area, canteens, etc.

Give every employee a personal letter fromthe managing director accompanied by acopy of the environmental policy with theirpay slip.

Publish the document in an internalnewsletter.

Include the environmental policyin induction training or hold formalenvironmental training to introduce thenew policy to all staff.

5.4.2 External communication

Decide whether you want to actively promoteyour policy or to provide it to external partiesonly upon request. If you want to promote thepolicy, this can be done by:

Putting a copy on your website;

publishing your new environmentalintentions in an external brochure/booklet;

writing an environmental commitment inyour organisations annual report; and

taking advantage of advertisingopportunities.

5.5 Close the loop

The policy must be reviewed on a regularbasis. To check that your organisationscurrent activities comply with theenvironmental policy, a review needs to beundertaken regularly usually on an annualbasis. If your organisations business activitiesor operations change significantly, the policymay need to be amended.

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6 Significance of environmentalaspects

6.1 Identifying your environmental aspectsand impacts

Identifying and understanding yourorganisations environmental aspects andimpacts will help you to reduce adverseimpacts on the environment. Preparing alist of aspects and impacts will also helpyou identify opportunities to reduce wasteand thus achieve significant savings throughreduced raw material purchase and waste

disposal costs.

The most important issue is to recognise andrecord your organisations environmentalaspects and impacts, and decide which onesare significant for your business.

The information gained during the initialreview will help you to prepare a list ofenvironmental aspects for your organisation.Aspects deemed significant for yourorganisation are the ones your EMS will seekto control.

Once you have started to identify yourenvironmental aspects, you can begin tocompile a register of them.

The Register of Environmental Aspectsshould contain:

a list of all potential environmentalaspects;

an assessment of their significance; and

the action you propose to take to reduce theimpacts associated with those aspects thathave been identified as significant.

If applicable, develop a process flow diagramshowing the main inputs and outputs to thedifferent stages of your process. Aspects can be:

direct, such as packaging waste and wateruse; and

indirect, such as the performance ofsuppliers, contractors, product design and

distribution.

Use Worksheet 3: Identifying significantenvironmental aspects(see Appendix) tohelp you compile your Register adaptingit as necessary to suit your organisationscircumstances.

Compiling your Register of EnvironmentalAspects may be the stage where you needmost help and could benefit from some freeadvice from WRAP. Call the WRAP Resource

Efficiency Helpline on 0808 100 2040 to findout more.

6.2 Identifying significant environmentalimpacts

Having established which aspects have orcan have an impact on the environment, thenext task is to assess which are significant foryour organisation. This will help you to decidethe key issues for your EMS to address andprioritise your actions for improvement.

Assessing significance will allow you to makeeffective use of your resources. It will enableyou to concentrate on taking action to reducemajor impacts and avoid having to try to dealwith all impacts (including those that are notdeemed significant).

Environmental aspects that exhibit significantenvironmental impacts must be consideredwhen setting the objectives of yourorganisations EMS.

To complete your Register of EnvironmentalAspects:

evaluate each of the environmentalaspects listed for its significance for yourorganisation; and

record whether or not you think theenvironmental aspect is significant and theactions to be taken to address it.

A formal EMS requires all the environmentalaspects of an organisation to be considered

including those that may not be significant(e.g. use of company/pool vehicles, use of paper,production of domestic sewerage and canteenwastes).

The informationgained during theinitial review willhelp you to prepare alist of environmentalaspects for yourorganisation.Aspects deemedsignificant for yourorganisation are the

ones your EMS willseek to control.

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EMAS requires a Register of EnvironmentalAspects to be maintained. If seekingcertification to ISO 14001, documentaryevidence is required to show that

environmental aspects have been considered.

6.2.1 Methods for evaluating significance

There is no set approach for evaluatingsignificance. You should choose the approachthat is most appropriate for your organisation,starting with an evaluation of significanceunder normal operating conditions.

One simple method is to judge thesignificance of the aspects against a numberof criteria (see Figure 3).

Numerical rating/weighting

Alternatively, you can develop your ownpoint-scoring system by awarding a numericalscore to each environmental aspect. Aspectswhich score more than an agreed amountcould be considered significant. In theexample in Table 2, each environmentalaspect is first awarded a score to reflect therelative importance under normal operatingconditions of:

legislation (current and forthcoming);

the severity of environmental impact (e.g.toxicity, acidity, greenhouse gas emissionsand ozone-depleting substances);

interested parties (e.g. the reaction of thelocal residents and environmental interestgroups); and

quantity (e.g. the volume of the wastestream or the frequency of occurrence atthe site).

The scores are then multiplied by aweighting factor, which reflects the overallimportance of the aspect at a particular siteor organisation. You should adjust theseas necessary to reflect your organisationsconcerns. Adding the four together producesa total score for this environmental aspectunder normal operating conditions. It is thenup to you to decide where to set the thresholdscore for environmental significance.

Repeat the exercise for all identified aspects.

Significant

Significant

Significant

Does the impact have thepotential to seriously damage

the environment?

Is the impact controlled

by current legislation?

Yes

Yes

Yes

No

No

No

Is the impact of concernto customers/consumers?

Identity impact

Impact is currentlynon-significant

(reassess periodically)

Impact is significant and shouldbe covered by your EMS

Figure 3: Flow diagram for assessing significance

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TIP: You may consider some factors soimportant that rather than applying aweighting, the aspect under considerationshould immediately be deemed significantif one particular factor has a high score.

GOOD PRACTICE: When an organisation isseeking certification/registration to a formalEMS standard such as ISO 14001 or EMAS,the evaluator requires evidence that theorganisation has assessed its environmentalimpacts formally and logically. A system thatrates and scores the relative significance ofeach aspect typically fulfils this requirement.

Different operating conditions can have atremendous effect on the significance of anenvironmental impact. For example, the useof returnable plastic packaging may not beconsidered to have a significant environmentalimpact under normal circumstances. However,when exposed to heat or it catches fire,noxious fumes may be released resulting inharm to human health or the environment, andpotential litigation from employees, membersof the public or regulators.

Therefore, it is important to also consideryour identified environmental aspects underother operating conditions. Other operatingconditions cover:

abnormal operations (e.g. factory start-upafter a holiday shutdown period);

accident/emergency (e.g. fire or accidentaldamage);

past activities (e.g. activities of former siteoccupants or burial of waste on site); and

planned activities (e.g. new product orproduction line, modified equipment or sitedevelopment).

Adding the scores together will produce atotal score under other operating conditions(see Table 3). This total score is used torank the environmental aspects under otheroperating conditions.

Under this system, a significantenvironmental aspect is one which scoresmore than a certain number of points undereither normal or other operating conditions.Some aspects may be significant in onlyone category, others in both. Using this

methodology, the maximum possible scoreunder either normal or other operatingconditions is 30.

It is up to you to decide where to setthe threshold score for environmentalsignificance.

Whichever method you decide to use toevaluate significance, it is important to recordthe reasons for your decision. If you needfurther advice on assessing the significanceof your environmental aspects, contact theWRAP Resource Efficiency Helpline on0808 100 2040.

Table 2: Matrix to score an environmental aspect under normal operating conditions

Environmental aspect

Score Weighting factor

3 2 1 0

Legislation Existing Impending None x 2 = a

Environmentalimpact

Knowndetriment

Possibledetriment

Limiteddetriment

Nodetriment

x 3 = b

Interestedparties

Considerableinterest

Moderateinterest

Littleinterest

No interest x 2 = c

Quantity High Medium Low Nil x 3 = d

Normal operating conditions Total score= (a + b + c + d)

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6.3 Review of Register of EnvironmentalAspects

Because the relative significance of your

environmental aspects may change over time,you should aim to review the list and significanceassessment regularly. New legislation, targetsbeing met or the introduction of new processesor facilities may affect the significance of youraspects, create new ones or eliminate others.For example, replacing cardboard transitpackaging with returnable plastic crates mayeliminate cardboard from the packaging wastestream.

GOOD PRACTICE: Review environmental

aspects and impacts at least once a year, andrevise or complete from new when:

projects or alterations are introduced,resulting in new or significantly modifiedactivities, products or services;

new information is received (e.g. impendingrelevant environmental legislation,complaints, enforcement notices, new ISO14000 series standards and technologicalprogress); and

substances that can have an adverse effecton the environment are introduced into thebusiness activities.Worksheet 3: Identifyingsignificant environmental aspects

This worksheet (see Appendix) has two parts:

Worksheet 3A :Contains a checklist ofbusiness areas giving rise to environmentalaspects.

Worksheet 3B :Use the first four columnsto list all your organisations environmentalaspects and impacts under differentoperating conditions. Then assess thesignificance of each aspect and recordyour conclusions in the fifth column. Usethe last column to document the proposedaction to reduce significance.

Worksheet 3Bforms your Register ofEnvironmental Aspects.

Table 3: Matrix to score an environmental impact under other operating conditions

Environmental aspect

Score

12 6 3 0

Abnormaloperations

Increasedenvironmentalimpact

No change Reducedenvironmentalimpact

= a

Accident/emergency



= b

Past activities Evident/requires action

Possibledamage/

difficult toevaluate

No damage = c

Plannedactivities



= d

Other operating conditions Total score= (a + b + c + d)

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7 Register of Legislation

7.1 Listing relevant legislation and otherrequirements

The pace of quantity, complexity and rangeof regulations is growing all the time in theenvironmental field. Increasingly stringentand far-reaching environmental legislationhas come from Europe and the UK.Additionally, the enforcing authorities haveshown that they will not hesitate to prosecutewhen necessary.

Therefore, regardless of whether or not you havean EMS, it is important for your organisation to:

ensure it complies with UK environmentallegislation; and

be able to demonstrate compliance to theappropriate regulatory authorities.

Maintaining a Register of Legislation canhelp your organisation to comply with existinglegislation and make you aware of impending

legislation. This will also help you identify theprocesses with a significant impact on theenvironment.

Knowledge of relevant legislation is anessential requirement of any EMS andis a useful method of summarising yourobligations for compliance.

EMAS requires a list Register of Legislation of all relevant statutes and approved codesof practice (e.g. process guidance notes)relating to your activities, productsor services.

You do not need to hold full copies of allthese documents, but the relevant peoplein your organisation must understand theirrequirements.

However, you will find it useful to hold copiesof important legislation and documentsspecifying numerical limits and essentialtechniques.

Use Worksheet 4: Register of Legislationto help compile your record of key documents

affecting how your organisation operates(see Appendix).

Maintaininga Register ofLegislation can helpyour organisationto comply withexisting legislationand make youaware of impendinglegislation. This willalso help you identify

the processes with asignificant impact onthe environment.

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8 Objectives and targets

8.1 Setting objectives and targets

The aim of an EMS is to manageenvironmental issues so as to achievecontinual improvement. An EMS doesnot guarantee improved environmentalperformance; accidents and incidents canstill happen. However, it does allow quickdetection, mitigation and, if necessary,remediation of any pollution incident.

To bring about continual improvement, youneed to set specific objectives broken downinto realistic targets. These should be basedon the information collected during yourinitial review and should aim to address yoursignificant environmental aspects.

Objectives are the goals that theorganisation sets itself for achievingimproved environmental performance.They indicate the organisations aimregarding particular significant issues.For example, an objective could be toreduce waste going to landfill.

Targets provide interim points on the wayto achieving objectives. One objective canhave several targets. An example targetsupporting the objective above could be toreduce waste to landfill by 20% by 2015.

Objectives and targets can be used tomotivate employees and measure costsavings.

Where regulations, permits and consents

contain specific compliance requirements,these should be incorporated into yourobjectives and your mechanism for settingtargets.

Setting objectives and targets is based onthe information obtained during the initialreview and the identification of significantenvironmental aspects. When you setobjectives and targets, it is important to:

identify the individual or department

responsible for ensuring that they are met;

identify someone to oversee theimplementation of changes to ensure thattargets are met; and

ensure that the measures taken do notindirectly create another significantenvironmental aspect.

Identifying the opportunities to improveperformance requires communication withthe environmental management team. The

team members are the ones who know theprocesses and they will probably have ideasfor improvement.

TIP: If it will be expensive or difficult toachieve a particular objective, and legislativecompliance is not an issue, you may find itmore worthwhile to give priority to some easiertargets. Quick paybacks will help to maintaininterest in the EMS and obtain commitmentfrom all levels of the organisation.

When setting targets, be SMART. All targetsshould meet these criteria:

S pecific each target should address oneissue only;

M easurable your targets should beexpressed quantitatively, for example 10%reduction/unit;

A chievable your targets must besomething you can achieve. For example, azero waste target is probably not achievablefor most organisations;

R ealistic your targets should bechallenging but not overly ambitious.Remember they can always be revised oncethey have been met; and

T ime-bound your target must be assignedan end date for delivery.

It is important that agreed objectives andtargets are communicated to all staff. Staffawareness and acceptance of these objectivesand targets are essential to their success.

Where regulations,permits andconsents containspecific compliancerequirements,these should beincorporated intoyour objectives andyour mechanism forsetting targets.

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Use Worksheet 5: Objectives and targets foran improvement programme(see Appendix),to help you record your objectives and targetsbased on your environmental policy, your

significant environmental aspects and yourRegister of Legislation. This will providea framework for the development of yourcontinual environmental improvementprogramme. Also decide and record thetimescale and responsibility for achievingthese targets.

Targets should be measurable in absoluteterms and be clearly documented, along withany assumptions necessary. For example,setting an energy reduction target of, say,

10% is vague and requires qualification.One obvious variable that affects energyconsumption is the level of production.

An emission reduction target should also bequantified in absolute and specific terms.Waste-related targets could be classified intotwo parts one concerned with reducing theamount of waste generated in relation to ameasure of production and the other withincreasing the proportion of residual wastethat is recycled.

Assessment-based objectives such assupplier evaluation, site drain surveys andraw material substitution should be brokendown into individual tasks with expected

deliverables and dates.

8.2 Continual improvement under ISO 14001and EMAS

To achieve certification/registration, it isnecessary to show that objectives and targetshave been set, and to demonstrate yourperformance towards achieving them. Youmust have a monitoring programme and keeprecords of your monitoring regimes.

Although there is a requirement for continual

improvement, there is no set standard orguidance concerning the rate at which youimprove. An organisation is free to decide itscontinual improvement programme, takinginto account the expectations of stakeholdersand other interested parties. For example,an organisation aiming to reduce its energyconsumption by 1% per year would not bepenalised by an evaluator compared withan organisation planning to reduce itsenergy consumption by 25% per year. Therequirement is merely to specify reductionlevels that are measurable and achievable.

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9 Management programmeand Management Manual

9.1 Developing an action plan

Once you have agreed your objectivesand targets, the next stage is to developa continual environmental improvementprogramme designed to give priority to keyareas for action and to deliver the targets youhave set.

When developing an environmentalimprovement programme, it is important to:

prioritise the areas in which improvementis needed;

set a realistic timescale and budget foreach objective;

ensure that you have the necessaryresources, such as manpower and finance;

assign responsibility for each objective;

obtain the support of management/employees for the improvements;

hold short and regular meetings to report

progress;establish new deadlines if deadlines provedifficult to meet; and

review and update the environmentalimprovement programme regularly.

TIP: Software packages are available thatcan provide a powerful and effective tool formanaging your environmental, quality andproduction information. These can be helpfulwhen implementing and maintaining a formalor an informal EMS. However, they are only as

effective as the person using them and shouldnot be used to provide a quick-fix solution forsomeone with little experience of environmentalmatters.

Although there is a requirement for continualimprovement, there is no set standard orguidance concerning the rate at which youimprove.

9.2 Management Manual

Documentation is necessary to describe andsupport the EMS. The Management Manual(sometimes referred to as the EMS Manual)forms the basis of your organisations EMSand should, therefore, be relevant to theoperations and processes employed.

The Manual:

provides a central point of reference to theimplementation and maintenance of theoverall system; and

acts as a signpost to other documentswithin the system. It is usually produced,maintained and controlled by theManagement Representative.

One possibility is to use a consultant to helpyou design and compile a Manual. If youdecide to undertake this task yourself, tryto keep the system as simple as possible.

Remember, the more procedures youproduce, the more you will have to control,maintain and audit.

TIP: Keep the Management Manual short anduse flow diagrams where possible to reducethe amount of text.

GOOD PRACTICE: A simple way of creating aManagement Manual is to follow the headingsset out in a recognised standard such as ISO14001. Under each heading, briefly describe

your approach to tackling that elementand signpost the location of supportingdocumentation.

Although thereis a requirementfor continualimprovement, thereis no set standard orguidance concerningthe rate at which youimprove.

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Your Management Manual, which can beeither paper-based or in an electronic format,describes how your EMS operates. It shouldcontain or include references to the location of:

the organisations environmental policy;

a chart showing the organisationalstructure;

a statement of the organisationsobjectives, targets and its environmentalimprovement programme;

the responsibilities and authority ofemployees involved in the EMS, includingthe Management Representative; and

documented procedures for all processes

and activities that have a significantpotential environmental impact.

9.3 Procedures

To monitor and control the impacts thatcertain processes or materials may haveon the environment, procedures should bedefined and made available for easy referenceat all times.

These documented procedures:

should be easy to understand;

should be updated as necessary;

should be written with a view to increasingefficiency and reducing waste; and

will ensure the smooth functioning of theEMS.

Procedures are usually split into:

system procedures those relating to theoperation of the EMS itself (e.g. auditingprocedures); and

operational procedures those relating tothe control of identified significant aspects(e.g. waste management procedures).

Examples of those areas for whichorganisations could require procedures aregiven in Table 4.

Use Worksheet 6: Procedure(see Appendix),as a template to help you prepare and recordyour procedures.

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Table 4: Examples of procedures

Area Example procedures

System procedures

Policy Environmental policy review

Training

Documentation control

Legislation Register of Legislation

Evaluating legislative compliance

Environmental aspects Register of Environmental Aspects

Environmental management Environmental audits

Management system review

Operational procedures

Emissions to atmosphere Emissions inventory

Emissions monitoring

Emissions inspections

Refrigerant control

Heating and other combustion equipment

Discharges to controlled waters Discharge to controlled waters inventory

Discharge monitoring

Energy Energy inventory

Energy monitoring

Energy auditing

Materials Raw material inventory

Packaging assessment

Products Written description of products

Wastes (solid and liquid) Waste classification

Waste handling and storage

Effluent monitoring

Area

Transportation Transportation inventory

Purchasing policy/driver training

Land Land and premises assessment

On-site use of herbicides, etc

Land investigation

Change Control of change

Environmental assessment of proposed changes/developments

Incidents Recording and reporting of environmental incidents

Environmental audits

Emergency Environmental emergency plan

Safe systems at work Safe systems of work

Unloading hazardous materials

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10 Audits and reviews

10.1 Aims and scope of an internal audit

The aim of an internal audit is to regularlyassess whether:

your site is operating according to theagreed policies, control systems andprocedures;

your site is conforming to plannedarrangements and legal requirements;

your site is conforming to the specificrequirements of formal EMS (e.g.ISO 14001 and EMAS); and

defined objectives and targets are being met.

The ISO series of standards ISO 14010, 14011and 14012 provide guidance on auditing. ForEMAS, the ISO standards are referencedwithin the Regulation and the evaluatorwill check audit procedures for complianceagainst these requirements.

Internal audits involve a systematic inspectionand comparison of actual operating methodswith the procedures specified in theManagement Manual. It should identify andhighlight where things are working well andalso identify where things need to be improved.

An audit may be performed against either aprocedure or an area of operation. The keyto a successful EMS is commitment from allemployees. If employees are not committed,the system will be difficult to implement or

maintain. Audits provide a valuable tool forgauging commitment within different parts ofthe organisation.

The key areas to assess during theenvironmental audit include:

compliance with procedures;

compliance with policy;

compliance with objectives and targets;

adequacy of controls;

adequacy of emergency procedures;

areas of lack of control or unacceptablerisk;

employee skills and training;

contractor behaviour and performance;

supplier behaviour and performance;

adequacy of communications;

whether the general layout of the siteposes a risk to third parties, suppliers,contractors or site visitors; and

whether there are any new potentialenvironmental risks.

It is essential that sufficient resources tocarry out the audit are made available. Thefindings and recommendations of any auditmust be reviewed and assessed. Any actionsshould be implemented according to aspecified programme. In some cases, actionwill need to be taken immediately (e.g. wherea lapse in procedures has led to possible non-compliance with legislative requirements).

10.2 Selecting auditors

The people selected to carry out internalaudits should:

have experience of carrying out audits andhave received appropriate training; and

not have direct management responsibilityfor the procedure or area being audited(i.e. be impartial).

Specifically, auditors need:

appropriate knowledge of environmentallegislation and issues;

knowledge of the relevant EMS standard(s);

understanding of the best environmentalpractices in the industry;

experience in auditing managementsystems; and

appropriate training to undertake the task.

More than one internal auditor may berequired, but this also allows cover forholidays and sickness. Colleagues in theindustry may be able to provide valuable

contacts and the evaluator may also be ableto advise you.

Internal auditsinvolve a systematicinspection andcomparison of actualoperating methodswith the proceduresspecified in theManagement Manual.

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10.3 The audit process

Good quality internal auditing will save time,effort and money as the certified accreditor/verifier should be able to use the resultswith confidence as the basis for their ownassessments.

A systematic approach should be taken thatincludes:

planning the audit;

preparing checklists, including the checksand verifications to be performed;

obtaining any necessary backgrounddocumentation (e.g. relevant procedures,emission data and site plans);

reviewing the EMS documentation;

conducting and documenting the audit;

identifying and summarising allnon-compliances;

requesting corrective action (i.e. completionof Corrective Action Request (CAR) forms);

completing administrative tasks (e.g.having the audit report signed off by therelevant manager); and

stating the date for the next audit andhighlighting if it is different to the audit

plan.

Undertaking an audit is straightforward.Determine which procedure or area you aregoing to audit according to the audit plan. Itis common practice to inform the managerresponsible for the area or procedure to beaudited in advance of the audit. This ensuresthat staff and documentation will be availableduring the audit, and that there is no conflictwith operational duties or requirements.

When undertaking the audit, keep it simple

by asking key questions about the significantareas being audited. You must satisfy yourselfthat work is carried out in accordance with theapplicable procedure and that the supportingevidence is genuine.

Read the procedure(s) applicable to that areaand then use Worksheet 7: Internal audits(see Appendix) to prepare an internal auditform by inserting appropriate questionsrelating to each section of the procedure(s)into the first column. In the second column,

use a simple yes or no answer to recordagainst each question whether or not the areaunder investigation conforms with that part

of the procedure. Where a no is recorded,state the reason for this decision in the thirdcolumn and whether corrective action isrequired.

Remember, the audit process is designedto provide objective evidence as to theeffectiveness of the EMS and not to apportionblame.

Try to audit people carrying out the processor working in the areas being audited.

Ask questions and observe. Record thereplies and your observations on the auditsheet accurately and at the time that you

are performing the audit.Check that you have filled in and answeredall sections before signing and dating theaudit form.

10.4 Non-compliance and corrective action

Non-compliances are failures within thesystem. Usually these relate to differencesbetween how duties are being carried out andthose set out in procedures.

When a non-compliance (i.e. a no on the

audit form) is recorded, it is the auditorsresponsibility to suggest a way of correctingthe fault and preventing it from happeningagain. The auditor should prepare a non-compliance report or CAR form thatdescribes:

what has gone wrong;

how the fault will be rectified;

who will do the remedial work;

when it will be done (i.e. the timescale forimprovement); and

actions that can be taken to prevent thefault from happening again.

This logical and straightforward processis crucial to the success of your continualimprovement programme.

TIP: A non-compliance is sometimes due toa problem with the wording of a procedurerather than incorrect performance. In thiscase, the written procedure should bemodified to improve the description of the

operating method.

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Observations recorded by the auditor mayrelate to areas in which there are no specificnon-compliances, but where the auditor feelsthat the system could be improved in some

way.

Use Worksheet 8: CAR form(see Appendix) todraw up your own corrective action request form.

Any corrective action should be agreed withthe person responsible for that area orprocedure.

10.5 Audit frequency

The frequency of audits will depend on the

significance of your environmental aspects,but all procedures should be audited at leastonce a year. The number of internal auditscarried out per month will depend on yourorganisations circumstances.

To comply with the requirements of EMAS, allparts of the EMS must be audited betweensuccessive Environmental Statements(i.e. at least once every three years).See Section 12.2for more information onEnvironmental Statements.

The Management Representative should usethe Register of Environmental Aspects toidentify:

areas of high risk (i.e. the most significantenvironmental aspects); and

areas where the organisation has failed tomeet legal requirements in the past.

The frequency and sequence of audits shouldbe compiled into an audit timetable whichshows the area to be audited, the date and

time, and the auditor(s) involved.

The audit timetable is normally preparedand co-ordinated by the ManagementRepresentative. The ManagementRepresentative is also responsible forcommunicating the results of the audit tosenior management.

A well-designed audit with suitable checklistsshould take between 20 and 40 minutes.However, the process may take between twoand three hours the first time each audit iscarried out.

10.6 Communicating and reporting

An audit report is essential to ensure thatthe results of the audit are communicatedeffectively.

The audit report normally consists of:

a brief description of the audits objectives;

a brief description of the areas that havebeen audited and who was involved inauditing them;

a review of the audited areas, highlighting

non-compliances (i.e. lapses in either-the content or implementation ofprocedures and records);

corrective actions agreed;-any other areas of potential risk; and-

an outline of the opportunities for-improvement (e.g. resource efficiencyand cleaner technology); and

a summary list of non-compliances.

10.7 Aims and scope of a managementreview

The management review allows seniormanagement to consider the effectivenessof the EMS and any changes necessary.

It is a formal evaluation of the status andadequacy of the organisations environmentalpolicy, systems and procedures in relation toenvironmental issues, regulations, changingcircumstances and continual improvement.

The management review should cover:

environmental performance and progressin achieving objectives and targets;

compliance with legislation;

results of internal audits and reports;

status on actions required in connectionwith non-compliances;

new processes and any changes to knownenvironmental issues;

any changes in circumstances such as

operating requirements;-

any third-party requirements such as-customers, suppliers, stakeholders,regulators or in response to complaints;

changes in legislation; and-

new technology;-

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the effectiveness of training;

the need for any revisions to yourenvironmental policy, objectives andtargets;

follow-up actions from previousmanagement reviews; and

recommendations for improvement.

Management review meetings should beattended by those with either executiveresponsibility or specialist responsibility.This would normally include:

the site director or most senior manager;

the Management Representative; and

line managers with defined responsibilities.

REMEMBER: These reviews also provide anopportunity to implement resource efficiencyand other programmes to deliver significantcost savings as well as ensuring continualimprovement in environmental performance.

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11 Training and awareness raising

11.1 Who needs to know what?

Some parts of the workforce will need moreinformation about environmental issuesthan others. The amount of information willdepend on the level of responsibility assignedto them.

TIP: Start by looking at job descriptionsand dec

WRAP Your Guide to Environmental Management Systems

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