3. Environmental Policy

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Verified EMAS Statement
16 March 2012
CE Rosser
EMAS Verifier
Highland Spring Ltd
Ochils Site Environmental
Statement 2011
TABLE OF CONTENTS
1. Purpose & Scope __________________________________________________ 3
2. Context __________________________________________________________ 3
2.1 Highland Spring Background____________________________________ 3
2.2 Highland Spring Operation _____________________________________ 3
2.3 Organic Accreditation _________________________________________ 4
3. Environmental Policy _______________________________________________ 5
3.1 Environmental Policy Statement _________________________________ 5
3.1 Policy Statement ___________________________________________ 5
4. Description of EMS ________________________________________________ 6
4.1 Significant Environmental Aspects and Impacts _____________________ 6
4.1.1 Catchment area boreholes _________________________________________ 6
4.1.2 Purchase of raw materials and services _______________________________ 7
4.1.3 Packaging the product ____________________________________________ 7
4.1.4 Admin _________________________________________________________ 7
4.1.5 Distribution _____________________________________________________ 8
4.1.6 Disposal _______________________________________________________ 8
4.1.7 General to the entire Site __________________________________________ 9
5. Targets and Objectives ____________________________________________ 10
6. Further Information________________________________________________ 13
6.1 Validation Statement _________________________________________ 13
6.2Contact Information __________________________________________ 14
Highland Spring Environmental Statement 2011
1. Purpose & Scope
This document is Highland Spring Ltd’s seventh annual Environmental Statement
and presents its performance for the period January to December 2011 at the Ochils
site in Blackford.
This environmental statement is part of Highland Spring’s overall commitment to
ensure that the impacts from all of our activities are fully understood and minimised.
2. Context
2.1 Highland Spring Background
Highland Spring was established in 1979 and commenced trading in April 1981. The
group bottles Natural Mineral Water, Spring Water and Bottled Drinking Water, in
accordance with Scottish Statutory Instrument 2007 No. 435 “The Natural Mineral
Water, Spring Water and Bottled Drinking Water Regulations (Scotland) Regulations
2007” (and subsequent amendments) which implement the European Directive
80/777/EEC and its modifying Directives 96/70/EC and 2003/40/EC as well as
Council Directive 98/83/EC.
The company is based in the village of Blackford, Perthshire, on the edge of the A9
approximately twelve miles from Stirling and twenty from Perth.
Highland Spring has two bottling sites in Blackford: the main Highland Spring site
with extensive warehouse space and the Gleneagles site (acquired in April 2001),
which produces its own stylish Gleneagles brand and “Water Media” products. This
EMAS statement covers both sites.
At these sites Highland Spring employs around 300 staff. The factories are
dedicated to the bottling of natural water in modern bottling plants.
2.2 Highland Spring Operation
The Spring Water regulations require water to be abstracted from an underground
source which is protected against pollution. Rainfall on the upper slopes of the Ochil
Hills percolates into the ground and flows through the rock strata downslope to the
boreholes. The regulations require that the product must be of potable (drinkable)
quality as it emerges from the ground. It is imperative that the risk of pollution of the
ground, and therefore the water, is kept to an absolute minimum.
On average the water takes 15 years to flow underground from the rock outcrop at
the top of the hill to the boreholes. During this time bacteria from the surface die off
and the water dissolves minerals from the rock. The water is protected from the
surface by a layer of impervious rock or clay above the water bearing rock.
Boreholes are used to abstract the clean water from deep underground to the
surface. They are constructed in such a way as to prevent water from the surface
contaminating the deep groundwater. The water is pumped to the factory through
underground stainless steel pipes, and therefore is not exposed to the air or
environment at the surface.
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Highland Spring Environmental Statement 2011
To ensure that no contaminants can enter the water, Highland Spring Ltd has
achieved organic certification for the hillside. This means that no weedkillers,
insecticides or fertilisers can be applied to the land. In addition to this Highland
Spring does not allow livestock, cultivation or housing on the land because these
activities can also pollute the water. Only a very limited number of maintenance
vehicles are allowed on the hillside.
Highland Spring is happy to see wildlife and walkers on the land as these do not
represent a risk to the product.
When the water reaches the plant it is filtered to remove any rock particles, but
undergoes no treatment before being bottled (except carbonation to produce our
range of sparkling products). Still and sparkling water is presented in a wide range of
packaging formats in glass and PET (a type of plastic) to suit all consumer needs.
2.3 Organic Accreditation
The Soil Association awarded Organic status
to the catchment area of 621 hectares in 2001.
In 2005 we gained approval for another 398
hectares to allow expansion of our sources. In
May 2008 another 30 hectares converted to
organic. Therefore in 2011 we had 1049
hectares which were organic.
Though
European and UK legislation does not make
provision to gain organic status for water,
Highland
Spring
is
demonstrating
its
commitment to the protection of the sources by gaining certification for the catchment
area. As a result of this we are able to include the following phrase on the labels;
“Naturally filtered through land certified as organic by the Soil Association and drawn
from a protected source, Highland Spring is 100% Scottish Natural Spring Water”.
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Highland Spring Environmental Statement 2011
3. Environmental Policy
3.1 Environmental Policy Statement
3.1
Policy Statement
Highland Spring Ltd was formed in 1979 and is located in Blackford, Perthshire. Our
modern production facility is located close to the Ochil hills, home to our organically
accredited catchment area which ensures the protection of our source of natural
water. Employing over 300 staff, we have the biggest UK produced brand of Bottled
Water with 95% of our output sold in the UK. The Gleneagles Spring Water plant was
acquired in April 2001 and is also located in Blackford. Both production facilities are
dedicated to the bottling of natural source water in a range of packaging formats to
suit all consumer needs.
1. Highland Spring is committed, without prejudice to the development and
sustainability of its business, to minimise the impact of its operations on the
environment.
2. Highland Spring will promote practices to ensure that the organisation meets
compliance, as a minimum standard, with all regulatory and legislative
requirements and will seek to achieve continual improvement in environmental
performance.
3. Areas of specialist responsibility are allocated to key personnel to monitor and
report on environmental achievement. The Environment Team, led by a senior
member of management, will carry out reviews of procedures and trends, setting
objectives and targets to effectively control waste, emissions, discharges, land
contamination and the consumption of materials, fuel and energy. Priority will be
given to ensuring the protection of the catchment area for our water.
4. In accordance with our continuing policy to protect the integrity of our Spring
Water, Natural Mineral Water and Scottish Natural Water sources and catchment
area, Highland Spring will endeavour to minimise adverse environmental effects
and prevent pollution in daily operations and any new developments of the
business.
5. Without compromise or restriction to trade and where economically viable
Highland Spring will address product development through the utilisation of
recyclable materials. These materials themselves and packaging components
may include recyclable materials, provided their use does not prejudice the
integrity of the product water.
6. Highland Spring will promote, in its staff training programmes, the implementation
of good environmental practices.
7. Highland Spring has an environmental policy, which is reviewed regularly.
8. A copy of this policy, which is subject to review, is available to all company
employees, suppliers and customers and to any other interested party.
CHIEF EXECUTIVE: Les Montgomery
DATE:
1st March 2012
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Highland Spring Environmental Statement 2011
4. Description of EMS
The following environmental management system has been developed to fit into
Highland Spring’s organisational format and conforms to the ISO14001 standard.
The system helps us to achieve continual improvement and control by utilising the
following components which are requirements of EMAS:
Area
Policy:
Manual:
Procedures:
Programme:
Audit:
Public reporting:
Description
This states the overall aim and commitments
This describes our compliance with EMAS Regulations and ISO
14001 Standards and links with the other parts of the system
These prescribe how certain activities (those that require control)
should be carried out. This includes waste disposal and
emergency procedures
This is an ongoing programme of objectives and targets to drive
improvement
Both internal and external audits are used to ensure that the
system is working efficiently and that the programme is
progressing
This statement outlines our significant environmental aspects and
current performance
The Environmental Delegate manages the system, scheduling yearly management
reviews.
4.1 Significant Environmental Aspects and Impacts
4.1.1 Catchment area boreholes
Activity
Impact / Control
Installation and use of boreholes
Pollution of catchment.
When installing boreholes we recognise
environmental risk to ground water and thus
this activity is strictly controlled.
Resource Use.
Our management regime for the source has
been developed with our Consultant
Hydrogeologist and ensures that the volumes
abstracted have no significant effect on the
environment.
Highland Spring has been
granted an abstraction licence by SEPA
(Scottish Environmental Protection Agency).
Potential pollution of groundwater.
There is no human habitation or farming on
the catchment area or use of pesticides,
herbicides or fertilisers use on the catchment
area. Part of the catchment is certified
Organic by the Soil Association since July
2001, with a later addition in August 2005.
Boreholes are constructed infrequently thus
there is little or no disturbance in the
catchment area. This has a positive effect on
the land which encourages a wide diversity of
Abstraction of groundwater
Catchment organic status
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Highland Spring Environmental Statement 2011
Activity
Impact / Control
flora and fauna.
4.1.2 Purchase of raw materials and services
Activity
Use and disposal of filters
Impact / Control
Landfill.
There are also various issues associated
with materials use (including natural
resources use, the energy used during
production and transportation issues).
Purchase of goods through our assessed By using vendor rating and a supplier
supply chain
questionnaire it is possible to create a
positive effect by encouraging our
supplier
chain
to
improve
their
environmental performance.
4.1.3 Packaging the product
Activity
Glass scrap
Impact / Control
Waste for recycling.
Any glass used on site that is not sent to
the customer is recycled. At Gleneagles
this does not happen due to the fact that
only small amounts of glass are
produced and thus not very much waste.
Also the glass used at H/S contains a
proportion of post consumer recycled
material.
PET Scrap (bottles or PET preforms) and Waste for recycling.
Shrink wrap
These items are all recycled thus
significantly reducing their impact on the
environment.
Oils for compressors
Contamination of land and water.
The oil is stored on site safely so as to
prevent pollution and is disposed of offsite.
Inks for date codes and inks used on the Contamination of water.
labels are produced off the premises and Inks are carefully controlled so as to
do not contain VOCs or heavy metals.
prevent pollution.
4.1.4 Admin
Activity
Printer/copier cartridge recycling
Impact / Control
Recycling prevents materials going to
landfill and being wasted.
Disposal of obsolete computers and Computers are sent for recycling. Other
other electrical equipment
equipment disposal complies with WEEE
regulations.
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Highland Spring Environmental Statement 2011
4.1.5 Distribution
Activity
Impact / Control
Accidental fuel / oil leaks from vehicles Contamination of land and water.
and delivery of heating oil/storage
Fuel and oil have the potential for water
and / or land contamination.
Use of contractors to transport finished Emissions from transportation contribute
product.
to global climate change and air quality
reduction.
Noise pollution is also
generated.
Efforts to improve transport efficiency
being made
4.1.6 Disposal
Activity
Impact / Control
Creation of mixed waste for landfill on Includes transportation emissions and
site
impacts associated with landfill (habitat
destruction, leachate production, land
contamination, methane production).
Cardboard boxes sold for re-use/returned Since these items are re-used or
to supplier/ cardboard sent for use in recycled this significantly reduces their
pulp
impact.
Plastic Packaging (internal)
Packaging going to the customer (glass Through lightweighting our product (see
and PET )
Achievements section) we have reduced
the amount of packaging sent to the
customer. Local councils often provide
Glass recycling facilities. Plastic in this
country is often not recycled but the
effect of it can be reduced if recycling
facilities are provided.
Other outgoing secondary and tertiary There are various issues associated with
packaging; shrink wrap, trays.
materials
use
(including
natural
resources use, the energy used during
production and transportation issues) but
the main issue is its end of life (i.e.
landfill).
Product pallets for the UK
These pallets work on a return principle
where they are re-used within the
system.
Diluted cleaning agents, Peracetic acid, These chemicals are carefully stored so
caustic hot wash and ozone
as to minimise the potential for pollution.
Ozone is generated electrically as and
when required.
Use of battery recharged forklifts
Our batteries last 4 to 5 years as they are
rechargeable. Batteries contain materials
harmful to the environment.
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Highland Spring Environmental Statement 2011
Activity
Track lubricant used to lubricate the lines
(conveyor belts) when glass bottles are
being filled
Impact / Control
A new dry lube system has been
installed which has a number of
environmental advantages.
These
include a reduction of water consumption
and elimination of detergent use. The
volume of trade effluent is reduced.
Burning of gas for heating the boiler.
The burning of gas produces greenhouse
Use of propane gas cylinders filled on gas which contributes to global climate
site for forklift trucks
change.
Asbestos roof at Gleneagles
Special care must be taken if the roof is
to be dismantled as it can cause harm to
human health and has to be treated as
special waste.
4.1.7 General to the entire Site
Activity
Gas oil heating boilers.
Accidental leakage of gas oil
Impact / Control
The burning of diesel produces
greenhouse gas, which contributes to
global climate change. The burning of
oil also produces SOx and NOx.
Highland Spring has three discharge In late 2007/ early 2008 the domestic
consents to the river Allan for the effluent was connected the Blackford
following activities listed below:
Waste Water Treatment Works. This
helps further reduce risk of contamination
 Production of domestic effluent of local water courses.
from our effluent treatment plant
Trade Effluent now uses the same route
 Trade effluent discharge
 Site drainage discharge which further reducing the risk levels for the
runs through petrol interceptors site.
into the Allan water
Gleneagles has one discharge consent The consents are still in place.
to the River Allan for the following
activity.
 Trade effluent discharge.
Employee travel to work
Many people employed by Highland
Spring live in Blackford. Those who do
travel to work independently contribute to
global climate change.
Metal scrap
There is little metal scrap The use of
natural resources without recycling puts
a strain on the environment. It also
creates landfill.
Use of domestic water supplies for Use of water has a relatively small
employee toilets etc
environmental impact in Scotland – due
to high rainfall rates. Impacts relate to
the use of a natural resource and water
treatment.
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Highland Spring Environmental Statement 2011
Activity
Use of energy on the whole site.
Blowmoulding which requires
water and uses electricity
Impact / Control
The use of electricity itself has no
chilled environmental impact; it is the source of
electricity
that
has
the
overall
environmental impact, including global
warming.
These activities with their associated impacts are determined through the use of a
procedure to define importance and also through the discussion within the
Environment Committee. This procedure takes into account the views of interested
parties, legal commitments, policy commitments and the potential for any emergency
situations. Our Environmental legal commitments are listed in our Register of
Legislation (this is available on request). Following an initial environmental review it
was determined that our most significant effects on the environment are our use of
energy, packaging (including waste) and transport. A management programme was
developed to control these with the help of managers, and objectives and targets
were set to reduce our impact. Our objectives and targets can be found in the next
section.
5. Targets and Objectives
New legislation (see below) requires reporting on defined parameters in a specific
way.
New EMAS Regulation EC No 1221/2009
This new regulation was adopted on 25 November 2009, and introduces new
Environmental Reporting requirements on participating companies.
Core
environmental indicators and methods of reporting them are specified. These are
laid out below as the Regulation requires. This information will provide a baseline for
future year on year comparisons, and will form the basis for our Objectives and
Targets reporting.
Energy Efficiency: Target 1% reduction per year
Total Direct Energy Use: 14,388.81 MWh of electricity. It does not include gasoil
which is used for heating purposes only.
Total Output:
248793 Tonnes of Water Bottled
Ratio:
0.058 MWh/Tonne of Water Bottled
This represents a 10.7% reduction from 2010 in power used per tonne bottled. Work
has been done to analyse power consumption in more detail, by function. Systems
have been installed to record consumption on an hourly basis and this is providing
detailed information on usage at different times.
No energy was from renewables.
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Highland Spring Environmental Statement 2011
Material Efficiency: Target 1% reduction per year
Total Material Use in Tonnes:
Glass
Plastic
Paper
5797.7
8733.1
1912.6
Total Tonnes of Water Bottled: 248,793
Ratio: Tonnes of Material per Tonne of Water Bottled
Glass
Plastic
Paper
0.0233 (reduction of 15% from last year)
0.0351 (reduction of 9% from last year)
0.0077 (reduction of 7% from last year)
These variances are due to changes in the sizes and types of products sold, and this
has the effect of altering the ratios.
Water: Target 1% reduction per year
Total water to the factory: 312,936 Tonnes
Total output:
Ratio:
248,793 Tonnes
1.26 Tonnes per tonne bottled which represents an increase of
0.2% on 2010. It is difficult to reduce this figure because our
water use is currently very efficient.
Waste: Target 1% reduction per year
Non Hazardous
Waste Produced in Tonnes
Plastic
Glass
Paper
Landfill
118.1
51.06
85.4
90.1
Ratio: Tonnes of Waste per Tonne of Water Bottled
Plastic
Glass
Paper
Landfill
0.00047
0.000205
0.00034
0.00037
The figures for the plastic and paper sent to the waste stream were slightly down on
last year, but glass has increased. None of these figures is significant. However,
there was a significant drop in the waste to landfill of 20%. This was achieved by
better control of material segregation.
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Highland Spring Environmental Statement 2011
Hazardous
Weight of hazardous waste in Tonnes: 1.79
Ratio: tonnes hazardous material per tonne of water bottled: 0.0000072
Biodiversity: no target set
Area of built up land:
23,211m2
Area of organic land: 10,484,200m2
Ratio: m2 land per tonne water bottled
Area of built up land: 0.09
Area of organic land: 42.14
This represents a slight decrease on last year, but is purely caused by the increase in
tonnage of water bottled between 2010 and 2011. There has been no change to the
size of the built up or organic land.
Emissions: Target 1% reduction per year
Greenhouse Gas Emissions
GHG emissions from use of electricity, gas oil and loss of refrigerant from chillers has
been calculated: 327207 tonnes CO2
Ratio: tonnes CO2 per tonne water bottled
CO2:
1.32
Air Emissions
Total gas oil used: 80.11 tonnes
Total NO2 generated:
Total SO2 generated:
Total Particulate Matter generated:
96kg
128kg
6.9kg
Ratio: kg material emitted per tonne water bottled
NO2:
SO2:
PM:
0.00039
0.0005
0.00003
This represents over a 50% decrease in emissions because of a large reduction in
the fuel oil used on site. This was achieved through close control and monitoring of
the use of space heaters, but also because the winter months in 2011 were
considerably milder than the extreme cold conditions of 2010.
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Highland Spring Environmental Statement 2011
6. Further Information
6.1 Validation Statement
ENVIRONMENTAL VERIFIER’S DECLARATION
ON VERIFICATION AND VALIDATION ACTIVITIES
Lloyd’s Register Quality Assurance Ltd., with EMAS environmental verifier registration number UKV-005 and accredited for the scope:
“The management and reporting of the significant environmental aspects associated with the
sources, bottling, packaging and distribution of still and sparkling natural waters.”
(NACE code C 11.07 - Production of mineral waters and other bottled waters):
Highland Spring Ltd
Stirling Street, Blackford Auchterarder, Perthshire UK
Registration number: UK-000122
meets all requirements of Regulation (EC) No 1221/2009 of the European Parliament and of the
Council of 25 November 2009 on the voluntary participation by organisations in a Community
Eco-Management and Audit Scheme (EMAS).
By signing this declaration, LRQA declares that:
the verification and validation has been carried out in full compliance with the
requirements of Regulation (EC) No 1221/2009,
 the outcome of the verification and validation confirms that there is no evidence of noncompliance with applicable legal requirements relating to the environment,
 the data and information presented in the Environmental Statement 2011 of the
organisation reflect a reliable, credible and correct image of all the organisation’s
activities within the scope mentioned in the environmental statement
This document is not equivalent to EMAS registration. EMAS registration can only be granted by a
Competent Body under Regulation (EC) No 1221/2009. This document shall not be used as a
stand-alone piece of public communication.

LRQA Ref No: LRQ4000559
Date of verification: 16 March 2012
Verification Expiry:
31 March 2012
Date of validation:
16 March 2012
Validation Expiry:
21 March 2012
C.E. Rosser, EMAS Lead Verifier
On behalf of LRQA Ltd.,
Hiramford, Siskin Drive,
Middlemarch Office Village
Coventry, UK
CV3 4FJ
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Highland Spring Environmental Statement 2011
6.2Contact Information
We are always keen to obtain feedback about our Environmental efforts, so if you
have any questions or comments please contact our Environmental Representative
through our head office as follows:
Highland Spring Ltd
Stirling Street
Blackford
Auchterarder
Perthshire
PH4 1QA
Telephone: 01764 660500
Website: www.highland-spring.com
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