ENVIRONMENTAL MANAGEMENT SYSTEMS
During the course we have encountered some of the impacts human activities have on the
environment. Some of the major impacts relate to industrial activity which, in a capitalist
system, is driven by returns on capital. Control and mitigation of this environmental damage
used to be considered an eternality to economic decision making. Nowadays, most large
companies realise that their environmental performance not only can be an important factor in
securing orders but often can bring about financial savings and efficiency gains through
reducing waste and energy bills.
The management of environmental performance is difficult as often the BPEO is not always
apparent. There is also a need to co-ordinate the decision making process and check that
particular objectives are achieved. It is also important that the achieving of objectives can be
demonstrated to shareholders and outside agencies. Therefore structured and accredited
EMS have been developed. These are generally based around the principles of Quality
Assurance systems where regular auditing and assessment of performance are carried out.
The rise of green issues in politics over the last 20 years first led to the EPA in the USA and
then organisations in Europe to adopt EMSs. There are several forms of EMS around the
world, but we will focus on the UK and Europe.
1. What is an EMS ?
Definition: EMS is a portfolio of tools and strategies for accomplishing the objectives set out in
the policies of an organisation for mitigation of environmental damage.
All EMS involve:
documentation of the system
defining roles and duties
training
communication strategies
commitment
periodic reviews
audits of what is actually happening
continual monitoring
2. Accredited EMSs
There are a series of available standards for implementing EMSs.
particular relevance to the UK are:
Those which are of
2.1. BS7750
The BS7750 for environmental control within the manufacturing and service sectors,
implemented in 1992 by The British Standards Institute, was one of the first comprehensive
EMS standards. It was an influential document in the development of internationally
recognised accreditation schemes for EMS. It is strongly linked with BS5750 Quality
Management. The BS7750 was also accompanied by a series of Sector Application
Guidelines(SAGs), including one for Construction, to assist in interpreting the guidelines to
different industries. The BS 7750 Standard, however, is viewed by many to be more stringent
than the subsequent ISO14001. For example, BS 7750 requires that an organisation compile
a register of its significant environmental effects, and a register of all legislative, regulatory,
and other policy requirements. In addition, BS 7750 requires an organisation to make its
environmental objectives publicly available.
2.2. ISO14001
Following the publication of the United Kingdoms BS 7750, a proliferation of national EMS
standards emerged, including standards from Ireland, France, South Africa, and Spain. The
various EMS standards did not all share the same requirements, and in some cases the
requirements were contradictory. It became clear that in order to facilitate international trade,
there would have to be one international EMS standard that would be accepted around the
globe. Thus the International Standards Organisation produced the 14000 series of
documents
In March 1997, BS7750 was replaced in the UK by ISO14001. This is an internationally
recognised standard and fed upon the development work of BS7750. The main specifications
of EMS are in the ISO14001 but there are other documents containing guidelines for EMS,
Environmental Auditing and Environmental Performance Evaluation.
2.3. EC Eco management and Audit Scheme (EMAS)
The EMAS evolved from the environmental agenda which formed part of the 1987 Single
European Act. Initially this was envisaged as a mandatory systems for auditing industrial
facilities but negative feedback resulted in a voluntary version being put to the Council of
Ministers in 1991.
2.4. Comparison between ISO14001 and EMAS
Although ISO14001 and EMAS are often viewed as competing forms of EMS there are
differences which actually make them complimentary:
2.4.1. Similarities
 both schemes are site based but require the off site influence of activities to be considered
 both define appropriate procedures for EMS rather than set goals
 both require a environmental policy statement to be publicly available and the setting of
objectives and targets
 both require the development of standard operating procedures and written work
instructions
 both emphasis the importance of communicating to employees their responsibilities,
objectives and contributions to the EMS
2.4.2. Differences
 Scope: ISO14001 aims to create a corporate wide EMS and applies to all organisations.
EMAS just relates to industry but aims to develop and maintain and environmental
protection scheme of which the EMS is a part. The BSI sees ISO14001 as a stepping
stone not an alternative to EMAS.
 Policy objectives and targets: ISO14001 requires continual improvement of environmental
performance while EMAS also requires environmental impacts are reduced to a minimum.
 EMAS also requires and annual report unlike ISO14001
 EMAS audits are more frequent and detailed and more information has to be released to
the public
3. Features of Implementing an EMS
In considering EMS implementation in detail we will focus on ISO14001.
ISO14001 Structure
3.1. Establishment of an Environmental Policy
About 48% of large European companies in Europe now have published Environmental
Policies. This sets the terms of reference for the EMS at the beginning and is the driver for
the project. It must contain a commitment to continual improvement and prevention of
pollution, also to comply with legislation and provides a framework for setting targets and
objectives. Some example policies are given at the end of the handout. This must be
communicated to all employees and be made publicly available.
3.2. Planning
In planning to implement an EMS companies have to undertake several stages of
development.
3.2.1. Review
Initially companies are required to undertake an environmental review of activities. This sets
the agenda for the EMS and examines:
Legislative/regulatory requirements
Identification of significant environmental aspects of operation
Examination of existing procedures
Examines feedback from previous incidents
These are examined in terms of
Air pollution
Water pollution
Solid waste
Land contamination
Raw materials/resource usage
Other issues
All aspects of the companies operation are included, so in addition to the manufacturing
process, areas such as finance, administration, personnel, support services and suppliers
should be examined.
This will require extensive internal consultation, legal advice, consideration of emergency
provisions and consultation with other interested parties.
There are several possible methods to assess significance of aspects, in a simialr manner to
the scoping stages of an EA
METHOD 1: use subjective judgment, e.g. through interviews, to rank aspects on a scale (e.g.
1-4) of significance or use a matrix to identify aspects
METHOD 2: use risk assessment, e.g. giving each aspect a rank 1-5 for:
H: hazard
L : likelihood of occurrence
S : size or frequency of the problem
The overall significance is assessed by taking the product:
C=HxLxS
This is then use to identify the priority areas for the EMS objectives and targets to address.
3.2.2. Determination of Environmental Objectives and Targets
Setting objectives and targets provides an interpretation of the policy, with clear goals, so that
each departmental management team knows their responsibility. Targets should be clear,
measurable and demanding.
Example targets:
Objectives
Reduce energy use
Targets
Reduce electricity use by 10% in 1996
Reduce natural gas use by 15% in 1996
Reduce usage of
hazardous chemicals
Eliminate use of CFC’s by 1997
Reduce use of high-VOC paints by 25%
Reduce hazardous waste generation
Reduce chrome wastes from plating
area by 50% in 1997
Improve employee awareness
Hold monthly training courses
of environmental issues
Train 100% of employees by end of year
Improve compliance with
wastewater discharge permit limits
Zero permit violations by end of 1997
Such objectives and targets require Environmental Management programmes to be
established which identify the function, level and time frame by which targets are achieved.
3.3. Implementation and Operation
The actual implementation of an EMS requires a clear system of structure and responsibility to
be established. This needs a management representative with overall responsibility to
oversee the EMS, key personnel identified and procedures to communicate particular
responsibilities to each employee. Also contractors working on site need to be made aware of
the requirements of the scheme
Installing training and awareness programmes is also a specific requirement of
implementation of EMSs. This requires identification of training, needs, development of a
training plan, verification to regulatory organisations, documentation and evaluation of training
given. Further documentation is required for establishment of external and internal
communication systems on environmental performance.
Documentation is the key theme in all EMS and control of this documentation is another area
for which a system (documented) is required.
All the operational aspects of the company require consideration with regard to control of
activities with procedures for preventing pollution, management structures to assure
conformance with requirements and strategic management. Documentation and procedures
are also required for emergency situations.
LOTS OF PAPER !!!!
3.4. Checking and Operation
Organisations are also required to establish and maintain documented procedures for
monitoring and measuring all activities which can have a significant impact on the
environment. This requires establishing performance indictors such as:
Quantities of raw materials/energy used
Emissions
Waste produced
Number of Environmental Accidents
% recycled waste
Vehicle km
Prosecutions
etc.
often expressed as units per kg of finished product.
This gives verifiable indicators of the companies environmental performance and is
accompanied with a documented QA procedure for calculating the indicators.
Procedures are also required to respond to poor environmental performance.
Maintaining records of the whole EMS and its implementation allows the paper trail to be
traced back to each activity, product or service to demonstrate compliance with the EMS and
assess if objectives and targets have been met.
Regular audits of the whole process are required (max 3y EMAS but related to the nature of
the operation with ISO14001).
3.5. Management Review
Regular management reviews of the EMS process are required to assess the progress
towards achieving policies and objectives. However, EMSs themselves are the subject of a
continual improvement process.
4. Reasons for Implementing EMS
There are several reasons and pressures why organisations adopt EMS.
considered as:
These can be
4.1. Stakeholder Pressure
The public perception of industrial activities is important to the long term viability of business.
This is especially important for the stakeholders be it employees, local residents or customers.
4.1.1. Society
The influence of public opinion at large on industrial activities is growing and more often these
days people want to see action of substance rather than glossy PR spin or purely a reaction to
particular problems. A prime example of public opinion affecting operational decisions is that
of the decommissioning of the Brent Spar oil storage facility by Shell UK. Inadequate
communication of the considerable research undertaken in to disposal options (or perhaps
inadequate research into public opinion) led to boycotts of Shell products across Europe.
Local populations are also becoming more aware of environmental impacts of local industrial
activities and are requiring more information on risk and sustainability of industrial impacts on
the local environment.
4.1.2. Corporate Citizens
Workforce morale is important to maintaining productivity. As workers are also local citizens
productivity is enhanced by a positive local image of the organisation. A poor environmental
track record will also make it difficult for an organisation to keep and recruit good employees.
4.1.3. Customers
Customers are potentially the largest driving force behind environmental performance. Image
of the company, and green consumerism, are important driving factors behind purchasing
decisions. Many companies are also concerned that suppliers and vendors minimise their
environmental impact so the resulting total impact of their activities are also minimised.
Research by 3M in Spain, Sweden, Germany and the Netherlands indicated that
environmental performance was the largest factor in 20% of purchasing decisions.
4.1.4. Regulators
Regulators are driving improvements in the environmental performance of organisations in
several ways. Perhaps the most obvious is in stricter legislation on discharges and waste.
However, schemes such as the EC eco-labelling scheme, have been promoting the provision
of more environmental information on products so that consumers can make informed
purchasing decisions. Poor environmental performance can also have significant impacts on
commercial development, and example of this is the ban on oil exploration on Federal land in
the USA after the Exxon Valdez tanker disaster.
4.1.5. Financial Institutions
Investors in companies are also driving environmental improvements. The growth of green
investors and an awareness among other investors that environmental performance is often
linked to financial viability has prompted companies to demonstrate their green credentials.
This is especially true of some insurance companies who are requiring high environmental
performance as a pre-requisite for cover after some very high claims for large scale
environmental disasters.
4.2. Strategic Considerations
There are also long term strategic considerations in adopting an EMS. It is often the case that
environmental quality and overall quality issues are linked.
4.2.1. Cost Avoidance
The initial costs of implementing an EMS can seem high to some companies. But this has to
be set against the potential costs of environmental clean up and fines if there is a serious
failure. Generally management systems are cheaper than emergency responses, such as
clean up or product recall. The EMS also gives documentary evidence of the efforts of a
company in the environmental field which can be used as evidence in the case of future
investigation or prosecution.
EMS can also allow strategies decisions to be made on investment, allowing expenditure to be
planned. Some times immediate savings can be made:
e.g. 1992 Nat West Bank initiated an Energy Audit of its 3400 buildings. It was identified that
for a capital outlay of £750 000 an 8.8% saving in energy could be made (£630 000 p/a
saving).
4.2.2. Pre-empting regulation
Improving environmental performance can also predict, influence and even head-off
regulation. Having an input at an early stage can help to avoid a confrontational relationship
with government and allow practical regulations to be developed.
5. Environmental Benefits of EMS
5.2. Internal
Within an organisation direct benefits to the environment result from:
Reduction in raw material use - less resource/energy use
Reduction of waste - to landfill etc.
Reduction in transport costs
Reduction in energy use - less greenhouse gases
5.1. External
Benefits also accrue from the influence of the EMS outside the organisation.
Upstream
Requirements that suppliers themselves have EMSs in place, or can verify their environmental
performance, mean that the environmental impact of raw materials and products is also
reduced.
Purchasing decisions enlightened by the implementation of the EMS are also likely to be
influenced by green issues
Downstream
In addition to less waste production, the duty of care principle requires companies not only to
seek appropriate waste disposal companies, but they must also investigate the procedures of
the company (to the extent of visiting disposal sites) as the producer is responsible for the
final disposal of the waste.
A more environmentally friendly product is likely to have less toxic components or be easier to
recycle, thus reducing downstream waste disposal problems.
5.3.Criticism
Of course EMS are not a panacea for all the environmental ills of the Planet, there are many
criticisms of the process. Especially when it come to the Quality Assurance Paper Trail based
approach of EMS:
What does accreditation mean ?
Accreditation basically means that the EMS procedures are in place. ISO14001 does not set
the targets, these are set by the industry themselves and are what they are judged against
(TQA ?????):
There is also criticism that the Rio concept of sustainability is not fully integrated as part of the
standards, and that the organisations do not have to aim for targets which are sustainable.
Other critics have argued that full Life Cycle Analysis and Management should be the basis for
assessing performance rather than site based polices and audits.
e.g. B+Q decided not to make BS7750 a pre-requisite for suppliers on the grounds that
accreditation procedures could distract companies from real environmental improvements
A recent book by Riva Krut and Harris Gleckman also argues that ISO14001 says nothing
about the environmental performance of a company and that the standard's requirements are
less stringent than many standards that companies and trade bodies impose on themselves.
They acknowledge the high profile the standard has gained since its creation, but say that
companies are signing up to it due to market pressure rather than a real intention to improve
environmental performance.
In response to these criticisms some countries, such as Denmark and Sweden, have adopted
an "ISO 14001 Plus" approach, requiring companies to fulfil the ISO requirements plus
additional demands.
6. TECHNICAL STRATEGIES
There are several technical strategies which can be used to achieve targets set in an EMS,
these include waste minimisation and Life Cycle Assessment.
6.1. WASTE MINIMISATION
The initial response to concerns about pollution in the 1960’s was to develop add-on
installations (or ‘end-of-pipe treatment systems’). However, the limitations of such an
approach have been recognised and since the mid-1970’s waste minimisation has been
identified as the only sustainable means of dealing with the waste problem. The main reasons
for this are:
1. The generation of large volumes of waste causes the depletion of largely non-renewable
resources.
2. The energy requirements for the transformation and upgrading of wastes is in proportion to
the quantities treated and rises exponentially with increasing dilution.
3. Increasing costs for the collection, treatment and storage of wastes make waste
minimisation attractive.
4. Increased legislation and public pressure seem likely to be only mitigated by waste
minimisation.
5. Waste equals inefficiency; therefore reducing waste increases efficiency and profitability.
The basic premise of waste minimisation is that prevention of the generation of waste is
preferable to attempting to clean it up after its production. This gives rise to a hierarchy of
preferred options:
6.1.1. THE WASTE MANAGEMENT HIERARCHY
6.1.1.1. Reduction at source
The reduction or elimination of waste at source; the most effective technique which should
always be considered first. Can be achieved by:
Process modifications
Housekeeping and management practice changes
Increases in efficiency of equipment
Recycling within a process
e.g. Purchasing control can prevent materials becoming waste by going out of date; less
packaging; process modifications to reduce by-products.
6.1.1.2. Recycling/Reuse
This is the use or reuse of a waste as an effective substitute for a commercial product or as
an ingredient or feed stock for an industrial process. This includes:
Reclamation of useful constituent fractions within a waste material
Removal of contaminants from waste to allow reuse.
e.g.
Recycling: paper, glass, metal; care must be taken to ensure recycling does not
increase waste or energy use.
Reuse: different use for waste; such as whey from cheese manufacture which can be
fermented to produce ethanol (and eventually a liqueur).
6.1.1.3. Treatment
Any method, technique or process that changes the physical, chemical or biological character
of the waste. The objectives of this are:
Neutralise the waste
Recover energy or material from the waste
Render the waste:
-non-hazardous
-less hazardous
-safer to manage
-amenable for recovery
-amenable for storage
-reduced in volume
e.g. end of pipe solutions biological treatment (aerobic, anaerobic - energy recovery), physical
treatment (adsorption, DAF etc.) and chemical treatment (precipitation).
6.1.1.4. Disposal
Disposal is the discharge, deposit, injection, dumping, spilling, leaking or placing of waste into
or on any land, or water, or into the air.
e.g. out-fall, landfill, incineration.
Clean Technology: These priorities have given rise to the concept of clean (or cleaner)
technology which is defined as ‘any technology or process which uses fewer raw materials,
and/or less energy, and/or generates less waste than an existing technology or process’.
The overall aim is to minimise the quantity and toxicity of waste produced so that it falls within
the assimilative capacity of the biosphere (and is therefor sustainable).
6.1.2. ELEMENTS OF A WASTE MINIMISATION STRATEGY
The strategies aimed at waste minimisation should follow the priorities laid out in the hierarchy
identified above i.e. possible options should be investigated with source reduction first,
followed by recycling then treatment. The basic parts of a waste minimisation strategy can be
summarised as follows:
1. Management Involvement - setting policy and guidelines
2. Setting of Goals
3. Selection of Targets
4. Technical and Economic Evaluation
5. Implementation of Programmes
6. Assessment and Monitoring
6.1.3. WASTE REDUCTION TECHNIQUES
The techniques available for waste reduction depend on the specific industry being examined.
Generally these can be broken down in to four major categories:
· Inventory Management
-Inventory control
-Materials control
· Production Process Modification
-Operation and maintenance procedures
-Materials change
-Process equipment modification
· Volume Reduction
-Source segregation
Concentration
· Recovery
-On-site
-Off-site
6.2. Life Cycle Assessment (LCA)
One technique used to investigate the environmental impact of a particular product is LCA
which used systems approach to investigate the inputs and outputs during each stage of
production, use and disposal of a project. The first reported LCA was carried out for coca-
cola containers in 1969. It is an area of on-going research and development which saw a
large expansion in the 1990's. A typical product has several stages in its life cycle, i.e.:
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Raw materials acquisition
Bulk material processing
Engineered and specialist material production
Manufacturing and assembly
Use and service
Retirement
Disposal
Every stage has material, labour and energy inputs and may have outputs in terms of waste,
within the cycle these wastes may be re-used or recycled to minimise the net output.
LCA can be wide ranging (see LCA of a detergent) and before the study is carried out
planning and screening stages are required to define the extent of the study. Accumulation of
data on the various stage of a product life can allow the various inputs and outputs to be
assessed and different material and production methods evaluated.